Future dental implant costs are compensable when accident injuries cause permanent tooth loss.

The claimant, aged 19 at the time, sustained injuries in a road accident on 27 March 2017 involving a KSRTC bus.

The Tribunal awarded ₹3,83,000, including ₹1,00,000 for pain and suffering, ₹2,50,000 for loss of amenities and related consequences, and ₹33,000 for medical expenses, with 6% annual interest.

KSRTC appealed against the quantum, while the claimant cross-objected seeking enhancement and applied under Order XLI Rule 27 CPC to produce a dental-clinic document estimating ₹2,00,000 for implants to replace five lost teeth.

Whether the Tribunal’s awards for pain and suffering, medical expenses, and loss of amenities were excessive or required enhancement

Whether the claimant should be permitted to produce the dental-clinic document as additional evidence and receive compensation for future tooth-implantation expenses

The proceedings arose under Section 173(1) of the Motor Vehicles Act, 1988, which provides for an appeal against a Claims Tribunal’s award; the cross-objection was brought under Order XLI Rule 22 CPC read with Section 173(1), and the request to produce additional evidence was made under Order XLI Rule 27 CPC.

The Court applied the principles of just compensation and assessment of reasonable future medical expenses on the evidence before it.

It cited no precedent or more specific doctrinal test.

The wound certificate recorded injury to the claimant’s lip and the loss or displacement of teeth; the Court concluded that five teeth had been lost.

In light of those injuries, it upheld the Tribunal’s awards for pain and suffering and medical expenses, and found the ₹2,50,000 award for loss of amenities and related consequences sufficient, including to account for the effect on marriage prospects.

It therefore declined separate awards for marriage prospects, special nutrition, attendant charges, or travel expenses.

Although the implant estimate had not been produced before the Tribunal, the Court accepted the claimant’s explanation for its omission and, given the established loss of five teeth, allowed the additional-evidence application and awarded ₹2,00,000 for future implants.

It awarded an additional ₹2,00,000 for future tooth implantation, without interest, directed KSRTC to deposit that sum before the Tribunal within six weeks, and ordered its release to the claimant.