Entitlement to compensation for future loss of income is not precluded by a post-accident increase in salary.

On January 4, 2016, the claimant (Respondent No. 1) was injured when a speeding truck (PB-10-FF-7191) collided with his motorcycle.

The claimant, a Dye Maker/Technician at Elecon Engineering, suffered serious injuries to his left limbs and ribs, resulting in 43% body disability.

The Motor Accident Claims Tribunal (MACT), Anand, awarded Rs. 16,78,272 with 9% interest, holding the truck driver solely negligent.

The Insurance Company appealed, contending that since the claimant remained in permanent employment with increasing pay post-accident, no compensation for "future loss of income" should be awarded, and that interest should not apply to future loss components.

1. Whether future loss of income can be awarded when the claimant’s actual salary increased after the accident.

2. Whether the claimant is entitled to interest on the amount awarded under the head of future loss of income.

The Court applied Section 173 of the Motor Vehicles Act, 1988, regarding appeals.

It relied on *Rajkumar v. Ajaykumar & Ors. (2011)* regarding the assessment of functional disability.

It relied on *Sarla Verma v. DTC (2009)* for the multiplier method (applying a multiplier of 9 for age 58).

Crucially, it cited *Mohd. Sabeer @ Shabir Hussain v. UPSRTC (2022)* to establish that an increase in post-accident income does not automatically preclude compensation for future loss of income.

Regarding interest, it followed *The Oriental Insurance Co. Ltd. v. Niru @ Niharika & Ors. (2025)*, affirming that interest runs from the date of the claim petition despite "future" loss being paid in advance.

The Court rejected the appellant’s argument that continued employment ignores the reality of physical impairment.

It reasoned that there is no legal bar to awarding future loss of income even if current earnings have not dropped, as disability impacts overall earning capacity and future prospects.

Using the claimant's net monthly income of Rs. 23,800 (after tax deductions) and a 43% disability rating, the Court found the Tribunal’s calculation of Rs. 11,05,272 (23,800 x 43% x 12 x 9) to be scientifically sound.

On the issue of interest, the Court held that since the insurance company could have settled the claim earlier and because "laws’ delay" should not prejudice the claimant, interest must be paid from the date of the petition.

It held that (1) compensation for future loss of income is maintainable despite a post-accident pay rise, and (2) interest is payable on the entire award, including future loss, from the date of the claim petition.

The appellant was directed to disburse the total compensation of Rs. 16,78,272 plus accrued interest to the claimant after deducting court fees.