A 25% addition for future prospects applies when calculating loss of future income from disability exceeding 20%.

Basappa appealed under Section 173(1) of the Motor Vehicles Act, 1988, seeking enhancement of compensation awarded for injuries sustained in a road accident on 24 November 2024.

The Tribunal had awarded ₹8,21,294, including compensation for permanent disability, pain and suffering, loss of amenities, and loss of income during the laid-up period.

The claimant sustained a head injury and multiple fractures, underwent surgery, and was hospitalized for nine days.

The judgment refers to the Tribunal’s award date as both 18 October 2024 and 18 October 2025.

Whether the compensation for loss of future income due to permanent disability required enhancement, including by using the appropriate notional income and adding future prospects.

Whether the awards for pain and suffering, loss of amenities, and loss of income during the laid-up period required enhancement in light of the claimant’s injuries and recovery period.

The appeal was brought under Section 173(1) of the Motor Vehicles Act, 1988.

The Court assessed compensation for disability by applying the multiplier method, using the claimant’s age, annual income, and percentage of disability; it applied a 25% addition for future prospects where the assessed disability exceeded 20%.

The Court also assessed compensation for non-pecuniary loss and laid-up-period income with reference to the injuries, treatment, hospitalization, and required recovery period.

No specific precedent is cited in the judgment.

The Court accepted the Tribunal’s multiplier of 13 for the claimant’s age of 46, but substituted the 2024 notional income of ₹17,000 per month for ₹16,500.

As the disability assessed at 26.6% was not challenged and exceeded 20%, the Court added 25% future prospects and recalculated loss of future income at ₹8,81,790.

Given the head injury, multiple fractures, surgery, and nine-day hospitalization, it increased pain and suffering to ₹80,000 and loss of amenities to ₹60,000.

It also allowed three months’ loss of income at ₹17,000 per month, while leaving the Tribunal’s award for attendant charges, transportation, and nourishing food unchanged.

The Court enhanced total compensation to ₹11,06,400, resulting in an increase of ₹2,85,106 over the Tribunal’s award.

The enhanced amount carries interest at 6% per annum from the date of the claim petition until realization, except for the 209-day delay in filing the appeal.

The insurer was directed to deposit the enhanced compensation with interest within six weeks, and the claimant was entitled to its release.