Supreme Court Enhances Compensation for Minor with 77% Disability: Riyas v. P.N. Shinosh (2025)

Case Name: Riyas v. P. N. Shinosh & Anr.
Citation: Civil Appeal No. 6544 of 2024; 2025 INSC 1303
Date of Judgment/Order: 10 November 2025
Bench: Hon’ble Mr. Justice K. Vinod Chandran and Hon’ble Mr. Justice N.V. Anjaria

Held: The Supreme Court while dealing with Motor Accident Compensation claim held that the appellant, a 14-year-old minor with 77.1% permanent disability caused by a motor accident, was entitled to a significantly higher amount of compensation than that awarded by the Tribunal and enhanced by the High Court. Applying the principles laid down in Pranay Sethi, Master Mallikarjun, Kajal, and subsequent precedents, the Court recalculated the compensation by taking the notional monthly income as ₹3,620, adding 40% for future prospects, applying a multiplier of 15, and adjusting for 77.1% disability. It further enhanced amounts under non-pecuniary heads such as pain and suffering, loss of amenities, loss of marriage prospects, medical expenses, attendant charges, and special diet/transportation, determining the total just compensation to be ₹15,13,337/-.

Summary: The case arose from a 19.04.2002 accident in which the appellant, a school-going minor, sustained serious injuries when the auto-rickshaw he was travelling in was hit by a lorry. The Motor Accident Claims Tribunal awarded ₹1,73,000, which the High Court enhanced by ₹5,75,883. In appeal, the Supreme Court found that the High Court had undervalued several heads of compensation despite the appellant’s substantial and lifelong disability. Considering modern jurisprudence on compensation for minors suffering permanent disabilities, the Court reassessed every component, including loss of future earning capacity, medical needs, functional disability, and overall impact on the child’s life and prospects.

Decision: The Supreme Court fixed the total compensation at ₹15,13,337/-, holding that the appellant is entitled to additional compensation of ₹7,64,454/- along with 8% interest from the date of the claim petition until realization. The Insurance Company was directed to deposit the enhanced amount into the claimant’s bank account within eight weeks and file proof before the Tribunal. The High Court’s judgment was accordingly modified, and the appeal was allowed.