Functional disability warrants compensation for daily-work inconvenience despite no proven income loss.

The claimant sustained injuries in a road accident involving a scooter ridden by respondent No. 1 and insured by respondent No. 2.

Medical evidence recorded permanent damage to the third and fourth fingers of his right hand, which impaired their function.

The claimant was employed in government service and continued to receive his salary.

The Motor Accident Claims Tribunal awarded ₹44,807 for treatment expenses, pain and suffering, and attendant and nutritional expenses.

He appealed, seeking enhancement on account of his permanent injury and its effect on daily activities.

1. Whether the Tribunal’s award required enhancement in light of the claimant’s permanent finger injuries and resulting day-to-day inconvenience, despite no established loss of income.

2. Whether additional compensation was warranted for future medical expenses and other consequences of the injury.

The appeal was brought under Section 173 of the Motor Vehicles Act, 1988, and the underlying compensation claim was made under Section 166.

The Court assessed compensation by considering the proved injuries and their consequences, including pain and suffering, assistance and nourishment, disruption to daily activities, and likely future treatment costs.

It found no basis for a separate award for loss of income where the claimant continued to receive his government salary.

The judgment cites no precedent.

Although the claimant’s government salary was unaffected, the medical evidence established that two fingers of his right hand were permanently damaged and could not function, and that his wrist was stiff.

The Court considered that these injuries would cause difficulty in daily activities and could entail future treatment and expenses not necessarily supported by receipts.

It therefore declined to calculate a separate loss of income for permanent disability but found the Tribunal’s award inadequate for the injury’s non-pecuniary and related consequences.

The Court enhanced total compensation from ₹44,807 to ₹1,20,000, awarding an additional ₹75,193.

The additional amount carries interest at 6% per annum from the date of the claim application until actual payment.

The Tribunal’s award was modified accordingly.