Loss of vision in one eye does not automatically establish 100% functional disability; earning-capacity loss depends on occupation and evidence.

On 23 December 2019, Salim, then working as a cleaner/coolie in a light goods vehicle, was injured when that vehicle struck a sugarcane-loaded tractor.

Sugarcane pierced his right eye, causing grievous injuries.

He claimed that he had sustained permanent disability and sought compensation.

The Tribunal awarded him ₹5,51,783, including ₹3,78,420 for disability.

Salim appealed, seeking enhancement; the insurer opposed the claim, including the disability assessment

1. Whether the compensation awarded by the Tribunal was inadequate and required modification

2. What order should follow from the Court’s determination of the compensation issue

Section 173(1) of the Motor Vehicles Act, 1988 provides for an appeal against a motor accident compensation award

Under Sarla Verma v. Delhi Transport Corporation, the applicable multiplier is selected by reference to the claimant’s age; for ages 26–30, it is 17

Under National Insurance Co. Ltd. v. Pranay Sethi, a self-employed claimant below 40 is entitled to a 40% addition for future prospects

Raj Kumar v. Ajay Kumar requires the court to assess the effect of permanent disability on the claimant’s actual earning capacity, rather than equating medical disability automatically with loss of earning capacity

The Court also considered Jayanandan v. Verkey, in which 100% functional disability was assessed in light of the claimant’s highly vision-dependent occupation; it distinguished that decision by the nature of Salim’s work

The judgment further referred to visual-disability guidelines and the Employees’ Compensation Act, 1993, including its 40% loss-of-earning-capacity figure for loss of one eye where the other eye is normal

The Court upheld the Tribunal’s assessment of monthly income at ₹13,250 because Salim had produced no evidence supporting his claimed income of ₹20,000; it also upheld the multiplier of 17 and the 40% future-prospects addition

It found the doctor’s disability assessment insufficiently supported because the certificate did not state the relevant visual-acuity details or comply with the cited guidelines.

Although the evidence recorded no light perception in the right eye, the Court considered that Salim’s work as a coolie did not demand the visual precision required in the diamond-cutting occupation in Jayanandan.

It therefore assessed whole-body disability at 25%, rather than 100%, and calculated future-income loss at ₹9,46,050

The Court also increased compensation for pain and suffering, laid-up-period income, loss of amenities, and attendant, food and nourishment charges, while leaving medical and conveyance expenses undisturbed

The Court enhanced the total compensation from ₹5,51,783 to ₹11,79,063.

The enhanced amount carries interest at 6% per annum from the date of the petition until payment, and the insurer was directed to deposit it with accrued interest before the Tribunal within three months of receiving the certified judgment