Supreme Court: Motor Accident Compensation Enhanced to ₹40.34 Lakh Plus ₹20 Lakh for Medical Expenses — Income of Paraplegic Victim Fixed Higher Than Minimum Wages

Case Name: Sharad Singh (Dead) through LR v. H.D. Narang & Anr.
Date of Judgment: September 26, 2025
Citation: 2025 INSC 1164, Civil Appeal No. 8136 of 2024
Bench: Hon’ble Mr. Justice K. Vinod Chandran and Hon’ble Mr. Justice N.V. Anjaria

Held: The Supreme Court enhanced compensation payable to the family of a 20-year-old accident victim, who lived paraplegic for two decades before his death, from ₹32.46 lakh to ₹40.34 lakh with 9% interest, along with an additional ₹20 lakh for medical expenses. It held that the High Court erred in pegging his income at minimum wages of ₹3,352, since as a final-year B.Com student enrolled with ICAI, he had bright prospects. Adopting ₹5,000 per month as notional income with 40% future prospects, the Court recalculated loss of income at ₹15.12 lakh, applying the Pranay Sethi (2017) principles. It further directed the insurer to reimburse ₹20 lakh towards verified medical bills for long-term treatment.

Summary: The accident occurred in 2001 when a car hit the motorcycle on which the victim was riding pillion, leaving him with 100% disability. He remained bedridden until his death in 2021. The Tribunal initially awarded ₹18.03 lakh, which the High Court enhanced to ₹32.46 lakh, including ₹14 lakh under conventional heads and ₹11.22 lakh medical expenses. On appeal, the family sought higher computation of income and recognition of further medical bills. The insurer objected, citing treatment at Goa instead of Delhi and difficulties verifying bills, but the Court rejected this, noting insurers have offices nationwide. Accepting that the victim could reasonably have earned ₹5,000 as an accountant in 2001, the Court enhanced compensation. It also allowed ₹20 lakh medical expenses verified by the insurer, payable within four months without interest, but carrying 9% interest if delayed.

Decision: The Supreme Court allowed the appeal, modifying the award to ₹40.34 lakh with 9% interest from the date of petition till realization, plus ₹20 lakh towards medical expenses, payable within four months. It reaffirmed that victims’ academic potential must be considered in motor accident compensation calculations.