For minors with permanent disabilities, future income loss must be calculated using minimum wages, multiplier, and disability.

The claimant, a minor aged 13 at the time, sustained injuries in a road traffic accident on 4 February 2023, allegedly caused by the negligent riding of a motorcycle.

The Tribunal awarded him ₹2,14,400, including ₹27,300 for loss of future income due to permanent disability, and directed the insurer to pay the award with 6% annual interest.

The claimant appealed under Section 173(1) of the Motor Vehicles Act, 1988, seeking enhancement.

Whether the compensation for loss of future income due to the minor claimant’s permanent disability was correctly assessed.

Whether the compensation awarded under pain and suffering, loss of amenities, and other heads required enhancement.

The appeal was brought under Section 173(1) of the Motor Vehicles Act, 1988.

Relying on Hitesh Nagjibhai Patel v. Bababhai Nagjibhai Rabari & Anr., (2025) INSC 1070, the Court applied the principle that, for a minor injured in an accident, loss of future income due to disability is assessed by taking minimum wages, applying the appropriate multiplier, and accounting for the disability.

The Court used the 2023 minimum wage for skilled labour, ₹13,650 per month, a multiplier of 15, and 7% whole-body disability.

The Court accepted the Tribunal’s assessment of whole-body disability at 7%, based on the doctor’s evidence of 23% disability to the left lower limb, but replaced the multiplier of 13 with 15 and applied the 2023 skilled-worker minimum wage; this produced future loss of income of ₹1,71,990.

In view of the claimant’s injuries, including a severely comminuted supracondylar fracture of the left femur, the Court enhanced pain and suffering from ₹25,000 to ₹60,000 and loss of amenities from ₹10,000 to ₹50,000.

It upheld the medical expenses of ₹1,37,100 and incidental expenses of ₹15,000, and allowed ₹27,300 for the parent’s loss of income during the claimant’s two-month recovery period.

The insurer was directed to deposit the enhanced amount with interest before the Tribunal within six weeks; the entire enhanced amount was to be kept in a fixed deposit in the minor claimant’s name until he attained majority.