Loss of future income for minor claimants must be assessed using skilled minimum wages and functional disability.

On November 9, 2011, the appellant, a 17-year-old Class XII student, sustained grievous injuries when a truck struck his motorcycle from behind in Okhla, New Delhi

The injuries resulted in the amputation of his right lower limb, leading to a certified 95% permanent physical disability

The Motor Accident Claim Tribunal (MACT) awarded a total compensation of Rs. 17,30,170 with 9% interest, holding the driver and owner liable for rash and negligent driving

The appellant filed this appeal seeking enhancement, arguing that the lump-sum award of Rs. 5,00,000 for loss of future income and the awards under non-pecuniary heads were inadequate

1. Whether the MACT erred in awarding a lump-sum amount for loss of future income instead of calculating it based on minimum wages and future prospects for a minor/student

2. Whether the compensation awarded under non-pecuniary heads, specifically loss of marriage prospects and disfigurement, required enhancement

The Court primarily applied the principles from Kajal v. Jagdish Chand (2020) and Baby Sakshi Greola v. Manzoor Ahmad Simon (2024), which establish that for minors or students, "notional income" should be based on the minimum wages of a "skilled" worker in the relevant state rather than a nominal fixed sum

The Court followed National Insurance Co. Ltd. v. Pranay Sethi (2017) regarding the addition of 40% for future prospects

Sarla Verma v. DTC (2009) for the application of a multiplier of 18 for a 17-year-old claimant

The Court observed that the appellant was a bright student whose career prospects were severely impacted by a 95% physical disability in his right lower limb

While the medical expert (PW-2) noted extreme difficulty in daily activities and driving, the Court determined that the functional disability affecting earning capacity should be assessed at 80%

The Court rejected the MACT's lump-sum award of Rs. 5,00,000, ruling that the calculation must be scientific.

Using the minimum wage for a skilled worker (Rs. 8,112/month), the Court added 40% for future prospects and applied a multiplier of 18, resulting in a revised loss of future income of Rs. 19,62,455.04

Regarding non-pecuniary heads, the Court found the compensation for "loss of marriage prospects" and "disfigurement" to be meager and doubled them to Rs. 1,00,000 each to reflect the gravity of the permanent impairment

The Court directed the insurer to deposit the enhanced amount within four weeks and ordered a partial lump-sum release of Rs. 5,00,000 to the claimant, with the remainder to be secured in staggered Fixed Deposit Receipts (FDRs) to ensure long-term financial security