A post-award permanent disability certificate warrants remand for reassessment of motor accident compensation.

The appellant, Sri Sanjit Sarkar, sustained serious injuries in a motor-vehicle accident on 16.01.2019 and was assessed with 87% locomotor disability and 75% intellectual disability.

He filed a claim before the Motor Accident Claims Tribunal, West Tripura, Agartala, which awarded compensation by judgment and award dated 02.06.2026 in T.S. (MAC) No. 73 of 2021, relying on the disability certificate then available and proved through evidence.

The original disability certificate was valid for five years, up to 13.03.2025.

Subsequently, the Disability Board issued a certificate dated 06.11.2025 assessing the appellant’s overall disability at 93% and certifying it as permanent for life.

Aggrieved by the quantum of compensation, the appellant appealed, contending that the Tribunal had not considered the later permanent disability certificate.

Whether the subsequent disability certificate dated 06.11.2025, assessing the appellant’s overall disability at 93% as permanent, warranted reconsideration of the compensation awarded by the Tribunal?

Whether the matter should be remanded to the Tribunal for reassessment of compensation after giving the parties an opportunity to prove and contest the permanent disability certificate?

The Court applied the principle that compensation in a motor-accident claim must be assessed on the basis of the claimant’s proved disability and its consequences.

A subsequent medical or disability assessment indicating a materially different and permanent degree of disability may justify reconsideration of the quantum of compensation.

The Court further held that the disability certificate dated 06.11.2025 would have to be made admissible as legal evidence by examining the doctor who issued it.

The certificate itself recorded the assessment under the Rights of Persons with Disabilities Act, 2016 and the applicable Government guidelines.

The High Court found that the Tribunal had assessed compensation on the basis of the earlier certificate, which recorded 87% disability and was valid only for a limited period.

The later certificate, issued after further examination by the Disability Board, assessed the appellant’s overall disability at 93% and declared the disability permanent for life.

Since the degree and permanence of disability directly affected the computation of compensation, the Court held that the later certificate required proper examination and evidentiary consideration.

However, it directed that the issuing doctor must be examined before the certificate could be relied upon as legal evidence.

Accordingly, the Court considered a limited remand appropriate, while preserving the findings relating to the accident, negligence, and the insurer’s liability.

The judgment and award dated 02.06.2026 were set aside, and the matter was remanded to the Tribunal for the limited purpose of reassessing the compensation after examining and appreciating the disability certificate dated 06.11.2025.

The appellant was required to examine the doctor who issued the certificate.

The issues concerning the occurrence of the accident, negligence, and the insurance company’s liability were treated as settled and were not to be re-agitated.

The Tribunal was directed to provide both parties a reasonable opportunity and to dispose of the matter expeditiously.