Lifetime prosthetic compensation must account for five-year replacement cycles and maintenance costs.

The appellant, who was injured in a motor accident in 2015 and was 21 years old at the time, challenged the Motor Accident Claims Tribunal’s award dated 4 August 2016 in MACP No. 28/2016.

The Tribunal awarded compensation of ₹19,29,542 with interest at 9% per annum, assessing the appellant’s monthly income at ₹9,500, functional disability at 45%, and applying a multiplier of 18.

In appeal, the appellant sought enhancement for future prosthetic limbs and their maintenance, loss of marital prospects, future prospects, and attendant charges.

The Insurance Company remained unrepresented and the matter proceeded ex parte.

The High Court also considered the subsequent legal development concerning the replacement and maintenance of prosthetic limbs.

1. Whether the appellant was entitled to addition of future prospects to his income for computation of loss of future earning capacity.

2. Whether the compensation for loss of amenities of life and attendant charges required enhancement.

3. Whether separate compensation was payable for future replacement and maintenance of prosthetic limbs during the appellant’s lifetime.

4. Whether compensation was payable under the separate head of loss of marital prospects.

The Court applied the principles governing addition of future prospects laid down by the Supreme Court in National Insurance Co. Ltd. v. Pranay Sethi, (2017) 16 SCC 680, under which a 40% addition was applicable to the income of a 21-year-old claimant.

It relied on Mohd. Sabeer v. U.P. SRTC, (2023) 20 SCC 774, and the subsequently developed principles in Prahlad Sahai v. Haryana Roadways, 2026 SCC OnLine SC 651, recognising five years as a reasonable replacement period for a prosthetic limb, assuming a life expectancy of 70 years, and permitting consolidated compensation for replacement costs and maintenance.

The Court further applied the principle that compensation must be just and reasonable, while avoiding duplication of compensation under overlapping heads.

The Court retained the Tribunal’s assessment of 45% functional disability and multiplier of 18.

Since the appellant was 21 years old and earned ₹9,500 per month, it added 40% towards future prospects, increasing the notional monthly income to ₹13,300 and recalculating loss of future income at ₹12,92,760.

It declined compensation for loss of marital prospects because ₹3,00,000 had already been awarded for pain and suffering.

Considering the nature of the appellant’s disability, compensation for loss of amenities was increased from ₹1,00,000 to ₹1,50,000, while attendant charges of ₹30,000 were maintained as just and reasonable despite the absence of supporting evidence.

Applying Prahlad Sahai, the Court assumed a lifespan of 70 years; as the appellant was 21 at the time of accident, he would require approximately ten prosthetic limbs over the remaining 49 years, based on a five-year replacement cycle.

Since the cost of one limb had already been awarded, the cost of nine replacement limbs at ₹3,30,000 each, together with maintenance at ₹75,000 for each five-year block, was calculated at ₹37,05,000.

This prosthetic amount was directed to be deposited separately and did not bear retrospective interest.

The Court enhanced the compensation under the principal award by ₹89,360, revising the award to ₹20,18,902, with interest at 9% per annum from the date of filing of the claim petition.

The enhanced amount was directed to be deposited before the Tribunal within four weeks and released to the appellant in a lump sum.

Any unreleased balance of the original award, along with accrued interest, was also directed to be released.

In addition, the Insurance Company was directed to deposit ₹37,05,000 towards future prosthetic limbs and maintenance within six weeks; the amount was to be kept in an interest-bearing FDR and released only upon production of a verified original invoice and proof of payment from a reputed vendor.

The appeal was disposed of in these terms.