Loss of studies and marriage prospects may be compensated as loss of amenities of life.

Simran Kaur, then a minor, suffered grievous injuries in a bus–truck collision on 12 March 2016, resulting in 66% permanent disability.

The MACT awarded her ₹14,89,090 with 9% interest, including ₹4,00,000 for loss of studies and ₹2,00,000 for loss of marriage prospects.

The insurer appealed those two heads; Kaur cross-appealed, seeking increased compensation for future surgery, for which the Tribunal had awarded ₹1,00,000.

A hospital estimate and the treating orthopaedic specialist’s evidence put the proposed surgery’s cost at approximately ₹9,35,000–₹10,00,000.

Whether the Tribunal’s awards for loss of studies and loss of marriage prospects should be reduced.

Whether compensation for Kaur’s future surgery should be enhanced in light of the medical evidence and estimated cost.

Under the Motor Vehicles Act, 1988, compensation must be just and fair.

Applying Raj Kumar v. Ajay Kumar, (2011) 1 SCC 343, compensation for injury may include non-pecuniary damages for pain and suffering, loss of amenities—including loss of marriage prospects—and loss of expectation of life.

Loss of studies may be considered within the broader deprivation of amenities of life; the Court also referred to United India Insurance Co. Ltd. v. Sarfaraz Safi, 2026 SCC OnLine Del 6310, Satish Kumar v. Kanika Sibal, 2026 SCC OnLine Del 2441, and Niketa Chauhan v. Suresh, 2026 SCC OnLine Del 1459, concerning compensation for educational disruption and its consequences.

The Court upheld the awards for loss of studies and marriage prospects because Kaur’s 66% functional disability, impaired ability to walk and run normally, and loss of anticipated academic and sporting opportunities supported the Tribunal’s assessment of substantial deprivation.

It treated the two awards as compensating for losses falling within the broader head of loss of amenities and found no basis to reduce them merely because they had been separately itemised.

For future treatment, the specialist confirmed that the corrective surgery was complicated, prolonged, and reasonably estimated at approximately ₹9,35,000; the Court accepted the estimate of ₹10,00,000, including the cost of a single room, as reasonable in the circumstances.

It directed the insurer to deposit that sum with the MACT within four weeks, to be kept in an interest-bearing fixed deposit and released to Kaur upon production of hospital documents confirming that surgery had been planned.

Any unreleased balance of the original award, with accrued interest, was to be released to her as a lump sum; both appeals were disposed of on those terms.