Future-income compensation requires proof that accident-related disability impairs earning capacity.

On 30 March 2021, the three appellants were travelling in a Maruti Ertiga driven by respondent No. 1 when it left the road and overturned; each sustained injuries.

They brought separate claims in MVC Nos. 386/2021, 387/2021 and 388/2021.

The Tribunal awarded ₹30,000, ₹25,000 and ₹78,200 respectively, holding the respondents jointly and severally liable and directing the insurer to pay, with interest at 6% per annum.

The injured claimants appealed, seeking enhancement.

1. Whether the compensation awarded by the Tribunal in the three claim petitions was inadequate and required modification

2. Whether the Tribunal’s award of interest at 6% per annum required modification

The appeals were brought under Section 173(1) of the Motor Vehicles Act, 1988.

In assessing compensation for disability-related future income, the Court considered whether the evidence established functional disability affecting earning capacity; a medical disability percentage alone did not establish such loss.

For MVC No. 388/2021, the Court applied Sarla Verma v. Delhi Transport Corporation, 2009 ACJ 1298, using multiplier 9 for the claimant’s age group of 56–60.

It also used the Karnataka Legal Services Authority’s notional-income chart, fixing monthly income at ₹14,250 for an accident in 2021.

For the claimant in MVC No. 386/2021, the Court found that although she had sustained a clavicle fracture, the evidence did not establish functional disability affecting her earning capacity; it therefore declined future-income compensation but increased amounts for pain and suffering, laid-up-period income and loss of amenities, and allowed medical expenses.

In MVC No. 387/2021, the injury was simple, there was no fracture or evidence of hospitalisation, and the disability evidence was not supported by the record; the Court accordingly declined disability-based compensation but added the proved medical bills to the Tribunal’s global award.

In MVC No. 388/2021, the Court accepted 5% disability to the limb, applied the notional income and multiplier, and awarded future-income loss; it also increased or added compensation for laid-up-period income, pain and suffering, and loss of amenities and nutritional food.

On interest, the Court found no reason to increase the 6% rate and retained it.

The compensation was modified to ₹60,400 in MVC No. 386/2021, ₹32,565 in MVC No. 387/2021 and ₹1,46,200 in MVC No. 388/2021.

The enhanced amounts carry interest at 6% per annum from the date of the claim petitions until payment; the insurer was directed to deposit the enhanced compensation and accrued interest with the Tribunal within six weeks of receiving the certified judgment.