Chhattisgarh High CourtTransport, Maritime, and Aviation LawCivil Procedure and Evidence

Chhattisgarh HC Denies More Compensation To 15-Year-Old Accident Victim, Citing Simple Injuries And No Hospital Admission

SANTOSH DAS MANIKPURIv.GANESH SENGAR

Chhattisgarh HC Denies More Compensation To 15-Year-Old Accident Victim, Citing Simple Injuries And No Hospital Admission. SANTOSH DAS MANIKPURI vs GANESH SENGAR. Chhattisgarh High Court. LawLens
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In brief

The question

Whether the 247-day delay in filing the appeal should be condoned

The court held

The Court condoned the delay but dismissed the appeal at the motion stage as devoid of merit.

It also directed

The Tribunal’s award of ₹12,951 remained undisturbed.

01Facts

Tanuj Das Manikpuri, aged 15, sustained injuries in a road accident on 18 July 2020.

¶ 1–6

The Motor Accident Claims Tribunal awarded ₹12,951: ₹9,951 for medical expenses and ₹3,000 for physical and mental agony.

¶ 1–6

His claimants appealed under Section 173 of the Motor Vehicles Act, 1988, seeking enhancement.

¶ 1–6

The appeal was filed 247 days late; the High Court condoned the delay before hearing the appeal on admission.

¶ 1–6

02Issues

i.Whether the 247-day delay in filing the appeal should be condoned

¶ 1–3

ii.Whether the Tribunal’s award of ₹12,951 was inadequate and warranted enhancement

¶ 5–7, 10–11

03Law Applied

Section 173 of the Motor Vehicles Act, 1988 provides for an appeal against an award of a Motor Accident Claims Tribunal.

¶ 5

The Court applied no cited precedent or separately articulated statutory test for enhancement; it assessed whether the compensation awarded was justified by the evidence concerning the injuries and expenses proved.

¶ 10–11

Provisions in the judgment · 1 · Linked ones open on LawLens

Motor Vehicles Act, 1988 Section 173

04Reasoning

The Court allowed the delay application and condoned the 247-day delay.

¶ 3

On enhancement, it noted that the injured was not working, so loss of income could not be assumed.

¶ 10–11

The Tribunal had found the injuries to be simple; the medical records showed no hospital admission or grievous injury, and the medical bills totalling ₹9,951 had been considered.

¶ 10–11

In light of that evidence, the Court found the award just and proper, with no basis for additional compensation under other heads.

¶ 10–11

05Holding

The Court condoned the delay but dismissed the appeal at the motion stage as devoid of merit.

¶ 3, 11–12

The Tribunal’s award of ₹12,951 remained undisturbed.

¶ 3, 11–12
Chhattisgarh High Court

Original Court PDF

SANTOSH DAS MANIKPURIvsGANESH SENGAR

Chhattisgarh High Court · November 03, 2026

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