Future prospects must be added when calculating loss of future income for permanent disability exceeding 20%.

The claimant sustained injuries in a road traffic accident on 1 January 2019.

The Tribunal awarded him ₹6,75,428, including compensation for permanent disability assessed by reference to a monthly income of ₹14,000 and multiplier of 17.

Seeking enhancement, the claimant appealed under Section 173(1) of the Motor Vehicles Act.

The High Court considered the injuries, medical evidence and claimed disability.

1. Whether the compensation awarded by the Tribunal required enhancement, particularly in light of the claimant’s injuries and functional disability.

2. Whether the claimant was entitled to interest on the enhanced compensation for the appeal’s delayed filing period.

The appeal was brought under Section 173(1) of the Motor Vehicles Act.

In assessing compensation for loss of future income, the Court applied a multiplier of 17, based on the claimant’s age of 29, and used a monthly income of ₹14,000.

It assessed functional disability at 25% and added 40% for future prospects, given that the disability exceeded 20%.

The judgment cites no specific precedent.

The Court found the Tribunal’s multiplier and income assessment appropriate but concluded that the medical evidence—including loss of vision in the left eye and facial fractures—supported functional disability of 25%.

Applying the multiplier method and adding 40% future prospects, it recalculated loss of future income at ₹9,99,600.

It also enhanced compensation for pain and suffering, loss of amenities and the two-month laid-up period, while affirming the amounts for medical expenses and incidental expenses.

The Court excluded interest for the 473-day delay in filing the appeal, in accordance with its order on the delay application.

The Court increased total compensation to ₹13,04,948, an enhancement of ₹6,29,520, with interest at 6% per annum from the date of the petition until realisation, excluding the 473-day delay period.

The insurer was directed to deposit the enhanced compensation and interest within six weeks, and the claimant was permitted to withdraw the entire enhanced amount.