Functional disability in injury claims remains crystallised at the date of accident regardless of subsequent death.

On January 9, 2005, Ram Phool Sharma, a DTC employee, sustained severe head injuries after being hit by a Tata CNG bus.

He underwent multiple neurosurgeries at Apollo and Orchid Hospitals and remained in a near-vegetative state, unable to perform basic functions.

He eventually passed away on February 12, 2010, while still under treatment.

The Motor Accident Claims Tribunal (MACT) treated the claim as an injury case, awarding Rs. 15,02,000.

The Insurance Company appealed, challenging the multiplier and the nexus between injuries and death, while the claimants sought enhancement, arguing the death was a direct consequence of the accident.

1. Whether there existed a causal nexus between the accidental injuries and the victim's death five years later to justify death-related compensation.

2. Whether the functional disability was correctly assessed at 25% by the Tribunal given the victim’s prolonged vegetative state.

3. Whether compensation should be determined based on the status of the claim at the time of the accident or include subsequent events like death.

The Court applied the principle from Kirti v. Oriental Insurance Co. Ltd. (2021), which establishes that claims and legal liabilities crystallize at the time of the accident and post-accident changes should not ordinarily affect proceedings.

It also relied on Meena (Dead) through LRs v. Prayagraj & Ors. (2025), regarding the recovery of compensation that accrued to a deceased injured claimant's estate.

The court further applied the "Just Compensation" doctrine under the Motor Vehicles Act, 1988, as a beneficial legislation per Helen C. Rebello v. MSRTC (1999) and Ningamma v. United India Insurance Co. Ltd. (2009).

For quantum assessment, the Court followed the guidelines in Sarla Verma v. DTC (2009) and Pranay Sethi (2017) regarding multipliers and future prospects.

The Court found a clear causal nexus between the 2005 accident and the 2010 death, noting the deceased underwent continuous treatment, multiple surgeries, and never recovered from neurological deficits.

While acknowledging the "hybrid" nature of the case (injury followed by death), the Court followed the Kirti principle, ruling that the claim crystallized as an injury claim on the date of the accident and the awarded compensation forms part of the estate.

Consequently, the Court found the Tribunal’s assessment of 25% functional disability too low; given the victim's inability to independent function and the neurosurgeon’s testimony of no future improvement, the Court increased functional disability to 50%.

The Court also reviewed non-pecuniary heads, determining that the prolonged five-year suffering warranted significant increases in awards for pain, suffering, and attendant charges.

It held that the functional disability was 50% and enhanced the total compensation from Rs. 15,02,000 to Rs. 25,53,300 with 9% interest per annum.

Specific directions were issued for the apportionment of the enhanced Rs. 10,51,300, including a lump sum release of Rs. 2,00,000 to the claimants and the remainder in monthly Fixed Deposit Receipts. The Insurance Company retained its recovery rights.