Loss of future income is payable for assessed disability using an age-based multiplier.

The claimant appealed under Section 173(1) of the Motor Vehicles Act, 1988, seeking enhancement of compensation awarded by the Motor Accident Claims Tribunal for injuries sustained in an accident on 25 October 2017.

The Tribunal had awarded ₹1,92,125 with interest at 6% per annum.

The claimant challenged, among other things, the income adopted, the period allowed for loss of income during treatment, and the failure to award compensation for loss of future income.

The High Court considered the claimant’s injuries, the medical evidence, and the Tribunal’s assessment.

1. Whether the compensation awarded for loss of income during the laid-up period should be enhanced by reassessing monthly income and the period of incapacity.

2. Whether the claimant was entitled to compensation for loss of future income on account of disability.

The appeal was brought under Section 173(1) of the Motor Vehicles Act, 1988, which provides for an appeal against a motor-accident compensation award.

In assessing compensation, the Court applied the principles of determining reasonable income, the period of loss during recovery, and future loss of income by reference to monthly income, multiplier, and percentage of disability.

The judgment cites no specific precedent or further statutory provision.

The Court found that the Tribunal’s 15-day period for loss of income was inadequate and assessed the claimant’s notional monthly income at ₹11,000, rather than ₹10,000, in the absence of documents supporting the claimed earnings of ₹250 per programme.

It allowed three months for the laid-up period, awarding ₹33,000 under that head.

Given the claimant’s age and assessed disability of 18%, the Court calculated future loss of income as ₹11,000 × 12 × 14 × 18%, amounting to ₹3,32,640.

It left the other compensation heads unchanged.

The Court enhanced the compensation by ₹3,55,640, bringing the total award to ₹5,47,765, with interest at 6% per annum from the date of the petition until deposit.

The insurer was directed to deposit the entire compensation within eight weeks, and the Tribunal was directed to release the amount to the claimant upon proper identification.