Rahul vs. National Insurance Company Ltd. [August 09, 2024]
Background
Rahul, the appellant, sustained severe injuries in a motor vehicle accident on January 27, 2013, while riding as a pillion passenger on a motorcycle insured by the National Insurance Company Ltd. He filed a claim petition before the Motor Accident Claims Tribunal (MACT), seeking ₹20,00,000 in compensation. The Tribunal, after evaluating oral and documentary evidence, including a disability certificate indicating 50% permanent disablement, awarded him ₹5,38,872 plus 6% interest per annum, assessing his functional disability at 25%.
The insurance company appealed to the Karnataka High Court, which reduced the compensation to ₹4,74,072 by lowering the disability assessment to 20% without providing substantial reasoning. Dissatisfied with this reduction, Rahul appealed to the Supreme Court.
Key Issues
Whether the High Court was justified in reducing the disability percentage from 25% (as fixed by the Tribunal) to 20% while determining compensation.
The proper approach for courts in assessing disability and awarding compensation in motor accident claims.
Supreme Court’s Findings
Improper Reduction by High Court: The Supreme Court found that the High Court erred in reducing the disability percentage from 25% to 20% without assigning plausible or sufficient reasons. The Tribunal had already exercised caution by not adopting the full 50% permanent disability certified by the doctor, instead fixing it at 25% based on a holistic assessment of the evidence.
Primacy of Medical Evidence: The Court emphasized that medical evidence and the expertise of professionals who assess the extent of disability must be given due weight. Arbitrary reductions in disability assessment by appellate courts, without strong justification, are unwarranted.
Restoration of Tribunal’s Award: The Supreme Court set aside the High Court’s judgment and restored the Tribunal’s award, reaffirming the 25% disability assessment and the corresponding compensation of ₹5,38,872 plus interest.
Direction for Payment: The insurance company was directed to deposit the entire compensation, including interest as determined by the Tribunal, within four weeks, after adjusting any amount already paid.
Conclusion
The Supreme Court’s decision in Rahul vs. National Insurance Company Ltd. (2024) reaffirms the principle that disability assessments in motor accident claims must be grounded in credible medical evidence and that appellate courts should not interfere with such findings without compelling reasons. This judgment ensures fairer compensation for accident victims and clarifies the judicial approach to disability evaluation in personal injury cases.
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