Headline: Multiplier of nine applies for post-retirement loss of income for injured public sector employees.

The accident occurred on January 19, 2014, when the claimant, a 54-year-old Head Constable with the Delhi Police, was hit by a speeding Hyundai I-10 while on picket duty

The claimant sustained crush injuries resulting in the amputation of his right leg below the knee

A disability certificate assessed his permanent physical disability at 70% in relation to the right lower limb

The Motor Accident Claims Tribunal (MACT) awarded a total compensation of ₹41,66,835 with 9% interest, assessing functional disability at 70% and applying a multiplier of 11

The Insurance Company appealed the quantum of compensation, arguing that functional disability was overestimated and that no loss of future income occurred since the claimant remained in service until superannuation in 2018

1. Whether the functional disability of a field police officer should be equated to the medical physical disability of 70% for the purpose of compensation

2. Whether an injured person who continues in government service until retirement is entitled to compensation for loss of future income

3. What is the appropriate multiplier and percentage for future prospects in the case of a 54-year-old victim

4. Whether the claimant is entitled to enhanced non-pecuniary damages and costs for multiple prosthetic replacements despite the absence of a specific cross-appeal

The Court applied the principles from Raj Kumar v. Ajay Kumar (2011), which distinguishes between physical disability and functional disability (loss of earning capacity)

It relied on Sarla Verma v. DTC (2009) and Reshma Kumari v. Madan Mohan (2013) for the standardized multiplier method and future prospects

Regarding public sector employees, it followed Desh Raj Singh Gautam v. Sunil Kumar (2016) and Rajbir Singh v. National Insurance Co. Ltd. (2024), establishing that post-retirement loss of income should be calculated using a multiplier of 9 (for age 60)

The court invoked its duty to award "just compensation" under Section 168 of the Motor Vehicles Act as per Ningamma v. United India Insurance Co. Ltd. (2009)

For prosthetic costs and non-pecuniary heads, it followed Mohd. Sabeer v. U.P. SRTC (2023)

The Court upheld the 70% functional disability assessment, reasoning that a police officer's field duties require mobility and that amputation creates a "serious handicap" in the labor market even if the claimant is retained in a desk job

The Court modified the multiplier from 11 to 9, noting that since the claimant remained in service until age 60, the loss of earning capacity effectively begins post-retirement

The Court added 15% for future prospects to align with the "proximity to reality" principle

Addressing the "just compensation" mandate, the Court found the Tribunal’s award for prosthetics inadequate; based on a 70-year life expectancy, it factored in three replacements and annual maintenance

Non-pecuniary damages for 'pain and suffering' and 'loss of amenities' were increased to ₹2,00,000 each to reflect the life-altering nature of amputation

The Court significantly enhanced the award for the prosthetic limb and maintenance to ₹5,55,000 (an increase of ₹4,45,000)

The Insurance Company was directed to deposit the enhanced prosthetic amount into an interest-bearing account, to be released to the claimant upon production of original invoices; the overall interest rate of 9% per annum was maintained