Injured claimants below 40 years are entitled to 40% future prospects in compensation.

The appellant-claimant, aged 22 years, sustained a compound fracture of the left leg and other injuries in a motor accident on 15 March 2012.

A Medical Board certified him as having 28% permanent disability in relation to the left lower limb.

He was employed in a private printing press and claimed an income of ₹12,500 per month; however, in the absence of documentary proof, the Motor Accident Claims Tribunal adopted minimum wages for an unskilled worker, i.e., ₹7,020 per month.

The Tribunal assessed functional disability at 15%, applied a multiplier of 18, and awarded total compensation of ₹5,72,000 with interest at 9% per annum.

The claimant appealed seeking enhancement on account of future prospects and a higher assessment of functional disability.

Whether the claimant was entitled to an addition of 40% towards future prospects while computing loss of future earning capacity.

Whether the claimant’s functional disability should be assessed at 28%, corresponding to the permanent disability of the left lower limb, rather than 15% as assessed by the Tribunal.

The Court applied the principles governing computation of compensation under the Motor Vehicles Act, including assessment of loss of future earning capacity by considering income, future prospects, functional disability and the appropriate multiplier.

Relying on National Insurance Co. Ltd. v. Pranay Sethi, (2017) 16 SCC 680, the Court held that a 40% addition towards future prospects was applicable in the case of a claimant aged 22 years.

The Court also distinguished permanent medical disability from functional disability: the latter must be assessed with reference to the effect of the injury on the claimant’s earning capacity and actual work, rather than by mechanically adopting the percentage stated in the disability certificate.

The Court accepted the claimant’s contention regarding future prospects and added 40% to the monthly income of ₹7,020, resulting in an addition of ₹2,808 per month.

Applying the formula—monthly income including future prospects, multiplied by 12, 15% functional disability and multiplier 18—the loss of future income increased from ₹2,27,448 to ₹3,18,427.

However, the Court declined to substitute the Tribunal’s assessment of 15% functional disability with the medically certified 28% disability.

The medical evidence indicated that the disability certificate excluded the pain component and that the affected limb’s functioning was not necessarily inconsistent with work.

Further, no evidence established the precise nature of the claimant’s work in the printing press or demonstrated that his other work-related activities were impaired to a greater extent.

Accordingly, the Tribunal’s assessment of 15% functional disability was found reasonable.

The Court enhanced the compensation from ₹5,72,000 to ₹6,62,102, representing an enhancement of ₹90,102, by granting 40% future prospects while retaining the 15% functional disability assessment.

The Insurance Company was directed to deposit the enhanced compensation with accrued interest at 9% per annum before the Tribunal within four weeks, after which the amount was to be released to the claimant as a lump sum.

The appeal was accordingly disposed of, and pending applications, if any, were rendered infructuous.