Future prospects must be added to actual income for determining compensation in permanent disability cases.

On November 10, 2006, the appellant-claimant was traveling in an Indica car when a truck, driven by opponent No. 1 in a rash and negligent manner, collided with the car.

The appellant sustained grievous injuries, including multiple fractures, resulting in his right leg being shortened by two inches.

At the time of the accident, the appellant was 56 years old and employed as a Secretary at APMC, Borsad, earning a monthly salary of ₹35,391.

The Motor Accident Claims Tribunal (Main), Anand, in MACP No. 582 of 2007, awarded total compensation of ₹1,89,497 with 9% interest.

Dissatisfied with the quantum, specifically the omission of future loss of income and inadequate non-pecuniary damages, the claimant preferred this appeal.

1. Whether the appellant is entitled to compensation for "Future Loss of Income" despite being in a stable job at the time of the accident, and if future prospects should be added to the income.

2. Whether the compensation awarded under the head of "Pain, Shock, and Suffering" was just and adequate given the permanent physical disability.

The court applied the multiplier method for assessing future loss of income as established in Sarmai Verma v. Delhi Transport Corporation.

It relied on National Insurance Company Ltd. v. Pranay Sethi (2017) 16 SCC 680 and Sidram v. Divisional Manager, United India Insurance Co. Ltd. (2023) 3 SCC 439 to justify a 15% addition for "Future Prospects" for a victim aged between 50-60 years.

For the calculation of functional disability and loss of earning capacity, the court also referenced Soni Sharma v. Oriental Insurance Company Limited (2026) ACJ 109.

The court found that the Tribunal erred by failing to award any amount for future loss of income.

Upon reviewing the salary slips, the court determined the net monthly income to be ₹35,191 after deducting professional tax.

Following the Pranay Sethi mandate, the court added 15% to this income for future prospects, totaling ₹40,470 per month.

Utilizing the undisputed 20% functional disability and applying a multiplier of 9 (consistent with the appellant's age of 56), the court calculated the future loss of income at ₹8,74,152.

Regarding non-pecuniary damages, the court observed that the shortening of a limb by two inches and the prolonged hospitalization necessitated an enhancement under "Pain, Shock, and Suffering" from a "meagre" ₹15,000 to ₹50,000.

The court held that the appellant is entitled to an additional sum of ₹8,09,152 with interest at 9% per annum from the date of the claim petition until realization.

The Insurance Company was directed to deposit the additional amount within six weeks.