Lower-limb disability is assessed as one-third of the limb disability for calculating whole-body disability compensation.

The claimant appealed under Section 173(1) of the Motor Vehicles Act, 1988, seeking enhancement of the compensation awarded by the Senior Civil Judge and MACT, Chikkanayakanahalli, in MVC No. 242/2025.

The Tribunal had awarded ₹1,70,000 for injuries sustained in a road traffic accident.

The High Court recorded abrasions and swelling, a right tibia fracture, and medical evidence assessing 30% disability to the right lower limb.

The judgment gives conflicting accident dates: 15 September 2024 in its account of the claim and 29 May 2024 in its compensation analysis.

It also states the claimant was aged 46 in the cause title but aged 39 when determining the applicable multiplier.

Whether the Tribunal’s assessment of compensation for disability and other heads warranted enhancement.

Whether the claimant was entitled to compensation for loss of income during the laid-up period and increased future medical expenses.

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

In assessing compensation for permanent disability, the Court treated one-third of the assessed disability to a lower limb as disability to the whole body in this case; it applied a multiplier of 13 and a monthly notional income of ₹17,000 to calculate future loss of income.

The Court also assessed compensation for pain and suffering, amenities, laid-up-period income, and future medical expenses by reference to the injuries, hospitalisation, and medical evidence.

No precedent was cited.

Applying the multiplier method, the Court converted the doctor’s assessment of 30% disability to the right lower limb to 10% whole-body disability and calculated future income loss at ₹2,65,200 (₹17,000 × 12 × 13 × 10%).

It found the existing awards for pain and suffering, medical expenses, and attendant, conveyance, food, and nourishment charges adequate, but increased compensation for loss of amenities from ₹20,000 to ₹40,000.

Given the injuries, it allowed ₹34,000 for two months’ laid-up-period income and increased future medical expenses from ₹20,000 to ₹30,000 for the anticipated implant-removal operation.

The Court enhanced the total compensation to ₹4,49,200, an increase of ₹2,79,200 over the Tribunal’s award, with interest at 6% per annum from the petition date until realisation.

The insurer was directed to deposit the enhanced amount within six weeks, and the claimant was entitled to release of the entire enhanced compensation.

No interest was payable on the additional ₹10,000 awarded for future medical expenses.