Enhancing Compensation for Paraplegic Victims: Supreme Court Recognises Academic Potential and Medical Realities.


26 September 2025 Civil Appeals >> Civil & Consumer Law  

The Supreme Court, by a recent ruling, reviewed the principles of motor accident compensation in a case involving a paraplegic state after a road accident involving a 20-year-old student. The judgment stressed the need to assess realistically the earning capacity of a young victim with established academic potential, rather than applying mechanical minimum wage notifications.

The claim was made by a final-year commerce student who had also taken the Chartered Accountancy course. He was severely injured in the spinal cord (C4-5 fracture) when he was struck by an extravagantly driven car, rendering him completely bedridden from 2001 until his death in 2021. His mother kept pursuing the claim in his name even after his death.

 

 

Medical Expenses in Question:

One of the controversial points before the Court was the payment of medical bills. The Insurance Company had contended that a number of bills pertaining to treatment availed of outside Delhi, specifically in Goa, and were thus unverifiable. The Court did not accept this argument, noting that the insurer with outlets across the country could not disown verification obligations. It also accepted the reason given by the mother that the family had to relocate to Goa on medical recommendations because of Delhi's weather, which aggravated the victim's pneumonia.

The Court finally conceded that an extra Rs.20 lakhs was rightfully spent on the victim's long-term treatment for twenty years, in addition to what had been given by the High Court.

Earning Capacity and Future Prospects:

Another significant problem was the valuation of notional income. The Tribunal had fixed the monthly income of the victim at about Rs.3,350, which was the minimum pay given to a skilled worker in 2001. The High Court approved this method. But the Supreme Court called this approach too narrow, considering the educational background of the victim and the prospects of finding employment as an accountant, even if he had not become a Chartered Accountant.

The Court took Rs.5,000 a month as the notional income for 2001, deducting 40% for future prospects as per the ratio enunciated in National Insurance Co. Ltd. v. Pranay Sethi. Applying the multiplier of 18, the Court recalculated the loss of income to Rs.15.12 lakhs.

Traditional Heads and Ultimate Calculation:

The Court maintained the Rs.14 lakhs granted under traditional heads of attendant charges, pain and suffering, disfigurement, and loss of marriage opportunities. Apart from this, it granted Rs.11.22 lakhs towards medical costs already settled. Combined, the compensation was increased to Rs.40.34 lakhs with 9% per annum interest from the date of filing of the claim to realization.

Independent of this, the Court also ordered payment of Rs.20 lakhs towards medical costs after the High Court order with no interest burden if paid within four months.

Key Takeaways:

  • Courts are not obligated to limit notional income to statutory minimum wages if proof of greater academic or vocational potential is available.
  • Authentication of medical bills cannot be negatived by insurance companies purely on grounds of geographical location.
  • Long-term medical and rehabilitative expenses must be fully accounted for in cases of total disability.
The judgment reaffirms a compassionate, realistic approach in accident compensation law, balancing strict principles with the human impact of tragic accidents.