A rear-end collision does not establish rider negligence without evidence of following distance.

On 15 October 2023, the claimant, riding a motorcycle, collided with the rear of a lorry that had stopped suddenly at night. He sustained a displaced fracture of the left clavicle and sought compensation under the Motor Vehicles Act.

The Tribunal awarded ₹5,45,800 with interest at 6% per annum. The claimant appealed for enhancement, while the insurer challenged liability and the quantum awarded

Whether the accident was caused by the rash and negligent driving of the lorry driver

Whether the compensation awarded by the Tribunal was just and proper

Appeals against awards of the Motor Accident Claims Tribunal lie under Section 173(1) of the Motor Vehicles Act

In assessing negligence in a rear-end collision, the circumstances and evidence concerning the vehicles’ movements and distance between them are relevant; Nishan Singh v. Oriental Insurance Co. Ltd., (2018) 6 SCC 765, and Oriental Insurance Co. Ltd. v. TATA AIG General Insurance Co. Ltd., 2026 INSC 208, were considered in that context

Compensation for loss of future income was calculated using the claimant’s annual income, the applicable multiplier and assessed whole-body disability; the Court applied the 2023 Karnataka State Legal Services Authority notional income of ₹16,250 per month and multiplier 17

The Court upheld the finding of negligence because the claimant testified that the lorry stopped suddenly at night without its brake lights on, and the insurer and insured adduced no evidence that the motorcyclist was negligent.

The record did not establish the distance between the vehicles, distinguishing the cited precedents, which involved evidence on that point; the charge sheet and the lorry driver’s guilty plea and conviction further supported the Tribunal’s finding.

On quantum, the Court retained the awards for pain and suffering, amenities, and attendant and related expenses, but revised loss of future income using the prescribed notional income and multiplier, increased laid-up-period income to two months, and enhanced future medical expenses for implant removal.

It rejected the additional medical bills in Ex. P11 because they were unsupported by evidence

It enhanced the total compensation to ₹5,77,349, granting an additional ₹31,549 with interest at 6% per annum from the date of the petition until realisation.

The insurer was directed to deposit the enhanced amount with interest before the Tribunal within six weeks, and the claimant was permitted to withdraw it