Case Name: Parminder Singh vs. Honey Goyal & Others

Case Number: Civil Appeal No. [Arising out of S.L.P. (C) No. 4484 of 2020]

Date: March 18, 2025

Quorum: Justice Rajesh Bindal

 

FACTS OF THE CASE

 

The case revolves around the motor vehicle accident that resulted in a young athlete suffering from 100% permanent disability. Parminder Singh, who was a 21-year-old veterinary aspirant and a state-level volleyball player, was involved in a road accident on June 3, 2014. In the accident, his motorcycle was hit by a car. The severe injuries he sustained had further led to quadriplegia, which left him entirely dependent on full-time assistance. Therefore, seeking fair and just compensation, Singh had filed a claim with the Motor Accident Claims Tribunal (MACT). The tribunal had initially awarded him ₹5,16,000. Dissatisfied with the amount, he had appealed to the Punjab and Haryana High Court, which had further enhanced his compensation to ₹15,25,600. This was primarily focusing on the loss of income while leaving other damages largely unchanged. Further aggrieved, Singh had approached the Supreme Court seeking a more comprehensive evaluation of his claim with respect to his loses…

ISSUES

 

1. Whether the High Court underestimated Singh’s monthly income by assessing it at ₹5,600 despite his qualifications and career in the future.
2. Whether the High Court failed to account for future prospects and additional expenses related to his disability for the remaining lifetime.
3. Whether Singh was deserved to get the compensation for physiotherapy, medical expenses, and loss of marriage prospects due to the accident.

LEGAL PROVISIONS

 

1. The Motor Vehicles Act, 1988 – It governs compensation claims for motor accidents that occur.
2. The Compensation Principles under Judicial Precedents – It ensures fair assessment of economic and non-economic damages in accident cases.

ARGUMENTS

 

Appellant’s Arguments:

 

1. His monthly income was underestimated despite being an aspiring veterinary doctor, thus affecting the final compensation calculation.
2. The High Court had further ignored the future prospects and long-term medical expenses, which should have been considered before calculating the compensation. 
3. The Additional damages for attendant care, pain, suffering, and loss of marriage prospects were insufficiently considered and not fully calculated.

 

Respondent’s Arguments:

 

1. The High Court’s compensation was reasonable and it had further given that there was no documented proof of the pre-accident earnings in order to calculate his income correctly.
2. The Future medical and attendant expenses were being fully covered under the existing compensation already.
3. No further increase in the compensation was needed in the said case as all the important matters are already considered.

 

ANALYSIS

 

The Supreme Court, emphasized the importance of realistic compensation that accounts for the long-term impact and that of permanent disability. The Court found that the High Court’s evaluation was conservative and failed to acknowledge the financial implications of Singh’s severe condition. The income calculation of ₹5,600/month was too low and below the minimum wage for semi-skilled workers at that time period (₹7,227.75/month). The Court revised his monthly income to ₹7,500. Future prospects should have been included at the time of calculation. Applying a 40% increase for future earnings, his adjusted monthly income was computed as ₹10,500. A multiplier of 18 was correctly applied by the High Court, and the Court upheld this method. The Court significantly enhanced compensation under multiple heads, including future medical expenses, loss of marriage prospects, and pain and suffering, acknowledging the lifelong impact of the disability.

 

JUDGEMENT

 

1. The Supreme Court allowed the appeal and increased the total compensation to ₹36,84,000. This was the amount after the calculation of the amount considering his losses incurred. 
2. The insurance company was directed to deposit the enhanced amount into Singh’s bank account within six weeks. The interest on the compensation was to be paid at the same rate as awarded by the High Court in the said case.

 

CONCLUSION

 

This judgment talks primarily about the necessity of a progressive approach in determining accident compensation, for young individuals with promising careers. In the said case it aims at ensuring a holistic evaluation of economic and non-economic damages. Supreme Court set a significant precedent in motor accident claims, ensuring that victims receive just compensation aligned with their life circumstances and potential career growth are being entirely considered. This ruling also underscores the judiciary’s sensitivity towards disabled individuals, thereby also recognizing their long-term financial and emotional suffering altogether.

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WRITTEN BY POOJA PARAMESWARAN