Injury compensation may include reasonable incidental expenses and future medical treatment costs.

The appellant sustained a fracture to his right leg in a road accident on 9 October 2020 and underwent hospital treatment, including insertion of a rod.

He was admitted on several occasions for approximately 20–21 days and produced medical bills totalling ₹4,42,563.

He did not produce medical documentation establishing permanent disability.

The Claims Tribunal awarded ₹5,13,563.

The claimant appealed under Section 173 of the Motor Vehicles Act, 1988, seeking enhancement, including compensation for future medical expenses.

Whether the Tribunal’s award of ₹5,13,563 was inadequate in light of the claimant’s injuries and treatment, warranting enhancement.

Whether an amount should be awarded for future medical treatment and incidental expenses not supported by formal receipts.

The Court exercised appellate jurisdiction under Section 173 of the Motor Vehicles Act, 1988, to consider the claimant’s challenge to the compensation award.

It applied a case-specific approach to reassessing compensation across relevant heads, including medical and incidental expenses; it recognised that hospitalisation and treatment may involve reasonable out-of-pocket expenses for which formal receipts are unavailable, and that future medical expenses may be awarded in light of the circumstances.

The Court accepted the documented medical expenses considered by the Tribunal but found that the claimant’s repeated admissions and treatment justified higher amounts for attendant, transport, special diet, pain and suffering, and loss of income during treatment.

It also considered reasonable incidental expenses likely to have been incurred without receipts and awarded ₹30,000 for future treatment.

Because no medical certificate or other document established permanent disability, the Court’s reassessment was based on the injuries and treatment shown on the record.

The additional amount carries interest at 6% per annum from the date the claim application was filed until realization; the remaining terms of the Tribunal’s award remain unchanged.

The Registry was directed to communicate the enhanced amount to the claimant in Hindi Devanagari, with paralegal assistance if required.