An injured claimant remains entitled to future-income compensation despite continuing employment.

The claimant appealed under Section 173 of the Motor Vehicles Act, 1988, against the Motor Accident Claims Tribunal, Anand’s award dated 30 September 2016 in Motor Accident Claim Petition No. 105 of 2008.

The claimant contended that the compensation was inadequate, including under heads such as pain and suffering, transportation, special diet, and medical expenses.

The Insurance Company opposed enhancement. The Court noted that the accident-related facts and the liability of the owner and insurer were not disputed.

Whether the Tribunal erred in assessing the claimant’s compensation and whether the award required enhancement.

Whether the claimant was entitled to compensation for future loss of income, and, if so, in what amount.

Under Section 173 of the Motor Vehicles Act, 1988, an aggrieved claimant may appeal a Motor Accident Claims Tribunal award.

The Act is beneficial legislation, and compensation must be just, fair, reasonable, and assessed liberally rather than niggardly, with the Tribunal making a realistic assessment of the loss sustained.

The Court relied on Reliance General Insurance Co. Ltd. v. Priyanka Das, 2026 INSC 950, for the proposition that an injured person may be entitled to compensation for future loss notwithstanding continued employment, assessed on the basis of existing income and other relevant parameters.

The Court reviewed the Tribunal’s award and concluded that it had erred in assessing compensation, including by failing to award compensation for future loss of income.

Applying the principle in Priyanka Das, it included Rs. 5,36,055 for future loss of income and assessed total compensation at Rs. 6,02,327, comprising the other listed heads as well. After deducting the Rs. 66,272 already awarded, the Court found that an additional Rs. 5,36,055 was payable.

The Insurance Company was directed to deposit the enhanced compensation of Rs. 5,36,055 with interest at 9% per annum from the date of the claim petition until realization, within eight weeks of receiving the order. The Tribunal was directed to disburse the awarded amount, subject to verification, due procedure, and deduction of any unpaid court fees; the Tribunal’s remaining directions were left undisturbed.