A minor claimant’s future-income award must include future prospects and an 18 multiplier.

On 6 May 2009, the appellant, then aged 16 and working as a cleaner on a lorry, was injured when it collided with a parked lorry.

He sustained injuries resulting in amputation of his left arm and left foot.

He brought a claim under Section 166 of the Motor Vehicles Act.

The Tribunal found the insured vehicle’s driver negligent and awarded ₹8,15,000, holding the owner and insurer jointly and severally liable.

The claimant appealed, seeking enhancement.

Whether the claimant was entitled to enhancement of compensation, including reassessment of functional disability and future loss of income.

The Court relied on Hitesh Nagjibhai Patel v. Bababhai Nagjibhai Rabari, 2025 SCC OnLine SC 3446, for the principles that, when assessing compensation for a minor non-earning claimant, income may be assessed by reference to notified wages for a skilled worker, the multiplier of 18 applied, and future prospects added.

It also relied on Raj Kumar v. Ajay Kumar, (2011) 1 SCC 343, in awarding compensation for loss of amenities.

In assessing future loss of income, the Court considered the effect of the injuries on earning capacity while also accounting for the claimant’s ability to undertake alternative work.

The Court upheld the Tribunal’s monthly income assessment of ₹5,000 because there was no evidence of the applicable 2009 minimum wage and the claimant’s deposition also stated that income.

It found that the Tribunal’s 50% disability assessment did not adequately reflect the combined effect of the arm and foot amputations, and increased functional disability to 80%, while taking account of possible alternative employment.

Applying 40% future prospects, multiplier 18, and 80% disability, it assessed future loss of income at ₹12,09,600.

It retained the awards for loss of income during treatment and medical and incidental expenses, but enhanced compensation for pain and suffering, future medical expenses including artificial limbs, loss of amenities, and loss of marriage prospects.

Compensation was enhanced from ₹8,15,000 to ₹18,60,000, with interest at 6% per annum from the date of the claim petition until deposit, excluding the period specified in the Court’s order of 15 February 2024.

The insurer was not liable to pay interest on the amount awarded for future medical expenses.