Courts may enhance injury compensation for treatment-period income loss and unreceipted incidental expenses.

The appellant sustained skull fractures and other injuries in a road accident on 16 April 2025.

He was treated as an inpatient for approximately five days and produced medical bills totalling Rs. 52,571, but no evidence of permanent disability.

The Claims Tribunal awarded Rs. 75,071.

The appellant appealed under Section 173 of the Motor Vehicles Act, 1988, seeking enhancement, including compensation for loss of income during treatment.

The insurer opposed the appeal, maintaining that the award was just and proper.

1. Whether the compensation awarded by the Claims Tribunal was inadequate and warranted enhancement in light of the appellant’s injuries and treatment expenses.

2. Whether the appellant was entitled to compensation for loss of income during the period of treatment.

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

In assessing compensation, the Court considered the documented medical expenses and also recognised that an injured claimant may incur reasonable miscellaneous expenses during hospitalisation and treatment that are not supported by formal receipts.

The Court found that the claimant’s skull fractures and other injuries, together with his five-day hospital stay, supported an increase in certain compensation heads, although no permanent disability was established.

It retained the documented medical expenses as the basis for the medical-expense award but rounded that amount up from Rs. 52,571 to Rs. 55,000, and increased the amounts for an attendant, transportation and special diet, and physical and mental agony.

It also awarded Rs. 10,000 for loss of income during treatment, which the Tribunal had not allowed.

The appellant was awarded an additional Rs. 29,929, carrying interest at 6% per annum from the date of filing of the claim application until realisation; the remaining terms of the Tribunal’s award were left unchanged.