Commercial driver’s functional disability assessed at 100% of medical disability due to visual impairment's vocational impact.

The Appellant, a commercial driver, was injured on May 10, 2007, when a tractor (HR-10J-5802) driven at high speed in a zig-zag manner hit his RTV

The accident resulted in a 30% permanent physical disability in relation to the Appellant's right eye

The Motor Accidents Claims Tribunal (MACT) awarded a total compensation of Rs. 3,70,000, calculating functional disability at only 15%

The Appellant approached the High Court seeking enhancement, contending that the loss of vision in one eye renders him unable to drive commercial vehicles

1. Whether the functional disability of a commercial driver should be assessed higher than the medical disability when the injury directly impacts his core vocation

2. Whether the compensation awarded by the MACT requires enhancement based on a realistic assessment of loss of earning capacity

The Court primarily applied the principles regarding the assessment of future loss of earnings as laid down by the Supreme Court in Raj Kumar v. Ajay Kumar (2011) 1 SCC 343

This precedent establishes that the Tribunal must assess the "functional disability"—the actual impact of the physical impairment on the specific vocation and earning capacity of the claimant—rather than relying solely on the medical percentage of disability

The Court observed that for a commercial driver, unimpaired and effective vision is a prerequisite for the safe performance of duties

While the medical disability was certified at 30% for the right eye, the Court reasoned that such an impairment substantially impedes the Appellant’s ability to continue his specific profession as a driver

Applying the Raj Kumar principles, the Court found the MACT’s assessment of 15% functional disability to be insufficient and revised it to 30% to reflect the realistic impact on the Appellant's livelihood

Consequently, the "Loss of future income" was recalculated using the multiplier method (Income + Future Prospects × 12 × Multiplier × Functional Disability)

The High Court allowed the appeal and enhanced the compensation from Rs. 3,70,000 to Rs. 5,24,795

The Respondents were directed to deposit the enhanced amount of Rs. 1,54,795 with 7.5% interest per annum from the date of filing the petition before the MACT within four weeks

The Court further ordered the amount to be released to the claimant through structured Fixed Deposit Receipts (FDRs) to ensure sustained financial benefit