Injury compensation may include treatment-related income loss, future medical expenses, and loss of amenities despite no disability proof.

Both appeals arose from a road accident on 6 April 2022 and challenged awards of the Claims Tribunal dated 9 July 2024.

In MAC No. 1897/2024, Purushottam Kurre had sustained fractures in both arms and legs and other injuries, was hospitalised for about ten days, and produced medical bills totalling approximately Rs. 2,41,738; the Tribunal awarded Rs. 2,49,500.

In MAC No. 1888/2024, Anil Kurre had sustained a fibula fracture, was hospitalised for about two days, and produced medical bills totalling approximately Rs. 41,001; the Tribunal awarded Rs. 47,400.

Both claimants sought enhancement, including compensation for loss of income during treatment, future medical expenses, and loss of amenities

1. Whether the compensation awarded to Purushottam Kurre for his accident-related injuries should be enhanced, including by awarding amounts for loss of income during treatment, future medical expenses, and loss of amenities

2. Whether the compensation awarded to Anil Kurre for his accident-related injuries should be enhanced, including under those heads

The appeals were brought under Section 173 of the Motor Vehicles Act, 1988

The Court assessed compensation by reference to the injuries, period of hospitalisation, documented medical expenses, and reasonable amounts for treatment-related incidental expenses and other relevant heads.

It noted that victims may incur out-of-pocket expenses for which formal receipts are unavailable

For Purushottam, the Court considered his multiple fractures, approximately ten-day hospitalisation, and medical bills, but noted that he had produced no documents or medical certificate establishing permanent disability.

It nevertheless found grounds to increase amounts for pain and suffering, medical expenses, attendant and transport expenses, and to award sums for loss of income, future medical treatment, and loss of amenities

For Anil, the Court considered the fibula fracture, approximately two-day hospitalisation, and medical bills; as no permanent disability was established, it made more modest awards under the relevant heads, including for treatment-related income loss, future medical expenses, and loss of amenities

In MAC No. 1897/2024, compensation was enhanced from Rs. 2,49,500 to Rs. 3,80,000, with an additional Rs. 1,30,500 payable with interest at 6% per annum from the date of the claim application until realisation.

In MAC No. 1888/2024, compensation was enhanced from Rs. 47,400 to Rs. 83,000, with an additional Rs. 35,600 payable on the same interest basis.

The remaining terms of the Tribunal’s awards were left intact

The Registry was also directed to communicate the enhanced amount to the claimant(s) in Hindi, with paralegal assistance if required