Functional disability of homemaker enhanced and future prospects realigned with Pranay Sethi principles.

On August 24, 2009, Kalpana Chauhan (claimant) sustained grievous injuries when the Wagon-R she was traveling in was hit by an offending vehicle (UP-86C-9390)

A medical assessment determined a 43% permanent physical disability in her left upper and lower limbs

The Motor Accident Claims Tribunal (MACT) awarded Rs. 1,73,750/- with 7.5% interest, assessing functional disability at 15% and future prospects at 30%

Both the claimant and the insurer filed cross-appeals challenging the quantum of compensation

A procedural error in a prior order dated March 18, 2026, which referenced the wrong case (Suit No. 339/2010), necessitated a recall and the issuance of this determinative judgment

1. Whether the future prospects and interest rate awarded by the Tribunal required upward revision to align with prevailing legal precedents and RBI rates

2. Whether the functional disability assessment of 15% was adequate given a 43% permanent physical disability in a homemaker

3. Whether the non-pecuniary damages for pain, suffering, and loss of amenities were sufficient

The Court applied the principles for calculating future prospects from National Insurance Co. Ltd. v. Pranay Sethi (2017) 16 SCC 680, which mandates 40% for an injured person aged 37

Regarding the assessment of functional disability and non-pecuniary heads, the Court relied on Raj Kumar v. Ajay Kumar & Anr. (2011) 1 SCC 34, which provides guidelines for correlating physical impairment to the loss of earning capacity and ensures adequate compensation for loss of amenities

The Court found the Tribunal’s assessment flawed on several counts. First, despite the 43% physical disability involving limb stiffness, the Tribunal’s 15% functional disability assessment was deemed too low for a homemaker; the Court increased this to 25%

Second, following Pranay Sethi, future prospects were raised from 30% to 40% based on the claimant's age (37)

Third, the interest rate was increased from 7.5% to 8.5% to reflect RBI fixed deposit rates prevalent in 2009

Lastly, the Court determined that the combined Rs. 25,000/- award for "pain and suffering" and "loss of amenities" was "highly inadequate" and granted Rs. 25,000/- for each head separately to ensure fairness under the Raj Kumar standards

The Insurance Company was ordered to deposit the enhanced amount within four weeks, to be released to the claimant via structured monthly Fixed Deposit Receipts (FDRs) of Rs. 10,000/- each; the interest rate to be 8.5% per annum from the date of the petition