100% functional disability compensation must include future medical expenses, attendant charges, and loss of amenities.

On November 15, 2005, the appellant sustained a head injury resulting in total paralysis after his scooter was struck by a car driven rashly and negligently by the first respondent

The appellant filed a claim under Section 166 of the Motor Vehicles Act, 1988, seeking ₹20,54,000 in compensation

The Motor Accident Claims Tribunal (MACT) awarded ₹4,56,340

On appeal, the Rajasthan High Court enhanced the compensation to ₹8,45,120 by accounting for 100% disability and future prospects

The appellant moved the Supreme Court seeking further enhancement, arguing that his monthly income was undervalued and compensation for attendant charges and pain and suffering was insufficient

1. Whether the notional income and multiplier applied by the lower courts were consistent with the evidence on record regarding the appellant's age and earnings

2. Whether the compensation awarded for future medical expenses, attendant charges, and loss of amenities was "just" in light of the appellant’s 100% functional disability

The Court applied the principle of "just compensation" under the Motor Vehicles Act, 1988

It utilized the Minimum Wages Act standards to determine the notional income of a skilled laborer in the absence of specific evidentiary proof of higher earnings

It further followed the established multiplier method for calculating the loss of future income and recurring future liabilities (such as attendant charges) based on the victim's age and life expectancy

The Court found that the notional income of ₹2,400 per month was correctly determined, as the appellant failed to produce evidence to justify his claim of earning ₹6,000

The age of 35 (and the resulting multiplier of 16) was also upheld as it was based on the appellant’s medical discharge ticket

However, the Court determined that the lower courts failed to provide adequate relief for the long-term consequences of 100% paralysis.

It increased future medical expenses to ₹7,00,000 to cover average life expectancy

Regarding attendant charges, the Court rejected the High Court’s lump sum of ₹1,00,000, ruling that a person with 100% functional disability requires daily assistance.

Using a rough estimate of ₹3,500 per month and applying a multiplier of 16, it recalculated this head to ₹6,72,000

Lastly, the Court awarded ₹2,00,000 for "loss of amenities," noting that the High Court had entirely omitted this head

The Supreme Court allowed the appeal and enhanced the total compensation to ₹23,69,996

It directed the respondents to pay the enhanced amount with interest at 6% per annum from the date of filing the claim petition until realization, within twelve weeks