Functional disability for sedentary professionals must account for mobility required to augment income and efficiency.

On May 10, 2012, Sanjay Sachdeva (the claimant) sustained grievous injuries when his motorcycle was hit by a rashly driven truck

The Motor Accident Claims Tribunal (MACT) awarded him Rs. 39,10,090 with 9% interest, assessing his benchmark income at Rs. 12,000/month and functional disability at 40%

The claimant, a 34-year-old with diplomas in fashion designing and computerized accounts, suffered 93% permanent physical disability in his right lower limb

Both the Insurance Company (challenging the income and disability assessment) and the claimant (seeking enhancement) filed cross-appeals

1. Whether the functional disability of the claimant should be assessed at 70% instead of 40% given the nature of his professional skills and physical limitations?

2. Whether the MACT erred in calculating the multiplier by adding years to the claimant’s age based on his recovery period?

3. Whether the claimant is entitled to future prospects at 40% as per established legal principles?

The Court primarily applied the principles from National Insurance Company Limited v. Pranay Sethi & Ors. (2017) regarding the grant of 40% future prospects for those under 40 years and the application of a fixed multiplier based on actual age at the time of accident

It further relied on Sandeep Khanuja v. Atul Dande (2017) and Mohd. Sabeer v. U.P. SRTC (2023), which established that even for "desk jobs," permanent disability in limbs significantly impairs the efficiency and earning capacity of a professional, requiring a higher assessment of functional disability

The Court rejected the MACT’s "illogical" method of increasing the claimant's age by 2 years due to his recovery period, noting it violated the standardized rules in Pranay Sethi

Regarding functional disability, the Court observed that though the claimant held an accounting qualification, his background in fashion designing and the necessity of movement for professional growth meant a 93% limb disability was severely restrictive

Applying the logic from Sandeep Khanuja, the Court held that limited mobility prevents a professional from effectively visiting clients or authorities, thereby justifying an increase in functional disability from 40% to 70%

The Court upheld the notional income of Rs. 12,000/month, noting that although ITRs were not formally proved, the acknowledgement receipts from the IT Department were credible

(i) Functional disability is enhanced to 70%

(ii) Future prospects of 40% must be added

The correct multiplier is 16 based on the age of 34

The total compensation was enhanced from Rs. 39,10,000 to Rs. 53,04,010 with 9% interest

The Insurance Company was directed to deposit the enhanced amount within four weeks, with specific directions for release through structured Fixed Deposit Receipts (FDRs) to the claimant