Uttarakhand High Court
Transport, Maritime, and Aviation LawCivil Procedure and Evidence

Compensation cannot be enhanced for unproved medical expenses beyond bills already considered by the Tribunal.

LAXMAN SINGH vs RELIANCE GENERAL INSURANCE COMPANY LIMITED

Uttarakhand High CourtJUDGMENT: September 18, 20262 MIN READSOURCE JUDGMENT
Compensation cannot be enhanced for unproved medical expenses beyond bills already considered by the Tribunal.. LAXMAN SINGH vs RELIANCE GENERAL INSURANCE COMPANY LIMITED. Uttarakhand High Court. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

On 10 August 2010, the claimant, Laxman Singh, was travelling on a motorcycle with Lalit Mohan when truck no. HR38H-6845, allegedly driven rashly and negligently, collided with the motorcycle. Lalit Mohan died at the spot and the claimant sustained serious injuries.

Source reference: pp. 1–2, para. 2

An FIR was registered and a charge-sheet was subsequently filed.

Source reference: pp. 1–2, para. 2

The claimant, then a Class IX student, alleged memory loss and difficulty in performing routine activities after the accident. He claimed approximately ₹1.5 lakh in treatment expenses and sought compensation of ₹3 lakh.

Source reference: p. 2, para. 2

The Motor Accident Claims Tribunal, Khatima, awarded ₹96,107, comprising ₹81,107 towards medical and hospital expenses, ₹5,000 for loss of income during hospitalisation, and ₹5,000 towards loss of earning and suffering.

Source reference: pp. 2–3, paras. 2, 7–8

The claimant appealed, seeking enhancement for allegedly unreimbursed CT-scan and other medical expenses and attendant charges.

Source reference: pp. 3–4, paras. 3–4
02

Issues

Whether the claimant was entitled to additional compensation for CT-scan expenses and other medical bills allegedly not considered by the Tribunal.

Source reference: pp. 3–4, paras. 3–4

Whether the claimant was entitled to additional compensation towards attendant charges.

Source reference: p. 4, para. 4

Whether the compensation of ₹96,107 awarded by the Tribunal required enhancement.

Source reference: pp. 4–5, paras. 9–10
03

Law Applied

The Court applied the compensatory principles governing claims under the Motor Vehicles Act, particularly that medical and incidental expenses must be established through evidence and supported by bills or other material on record.

Source reference: pp. 4–5, paras. 7–10

Compensation may be awarded only for expenses proved before the Tribunal; an appellate court will not enhance the award on the basis of unsupported assertions.

Source reference: pp. 4–5, paras. 7–10

No specific statutory provision or judicial precedent was cited in the judgment; the Court relied on the evidentiary record and the Tribunal’s assessment of the proved bills and expenses.

Source reference: pp. 4–5, paras. 7–10
04

Reasoning

The Court examined the Tribunal’s determination under Issue No. 6 and found that the hospital bills, medicine bills, and other documents placed on record had been considered, resulting in an award of ₹81,107 towards medical and hospital expenses.

Source reference: p. 4, para. 7

The Court further noted that the Tribunal had separately awarded ₹5,000 for loss of income during hospitalisation and ₹5,000 for loss of earning and suffering.

Source reference: p. 4, para. 8

Although the claimant asserted that CT-scan expenses and other medical bills had not been reimbursed, he was unable to identify or produce any document showing an additional proved expense omitted by the Tribunal.

Source reference: p. 4, para. 9

In the absence of supporting bills or other evidence, the Court declined to grant additional compensation for CT-scan expenses or attendant charges.

Source reference: pp. 4–5, paras. 9–10
05

Holding

The Court held that the Tribunal had properly considered the medical bills, hospital expenses, and other compensation claimed on the basis of the evidence available on record.

No material irregularity or error was found in the award of ₹96,107, and the claimant failed to establish entitlement to any enhancement.

Source reference: p. 5, para. 10

The appeal was accordingly dismissed, the original record was directed to be returned to the Tribunal, and any pending application was disposed of.

Source reference: p. 5, paras. 10–12
Uttarakhand High Court

Original Court PDF

LAXMAN SINGHvsRELIANCE GENERAL INSURANCE COMPANY LIMITED

Uttarakhand High Court · September 18, 2026

Click to open original judgment

Original judgment, available to read, download and summarize on LawLens.in

Click to open original judgment