Minor's compensation for permanent disability must be calculated based on minimum wages of a skilled worker.

The appellant, a minor (19 years old at the time of appeal but a minor during the Tribunal proceedings), was a pillion rider on a motorcycle on July 30, 2016, when a JCB vehicle (Reg. No. KA-07/M-6581) collided with it.

The appellant sustained grievous injuries resulting in 13% whole-body physical disability.

The Motor Accident Claims Tribunal (MACT), Mulbagal, awarded a total compensation of ₹4,40,671 via a judgment dated December 22, 2018, primarily applying the global compensation method for minors as per the Master Mallikarjun precedent.

The appellant sought enhancement, arguing that subsequent Supreme Court rulings mandate a specific calculation based on skilled worker wages.

1. Whether, in an appeal, the Court is required to examine the law as on the date of the judgment or as on the date of the appeal hearing.

2. Whether the compensation awarded to the appellant/claimant requires enhancement based on modern judicial principles for minor disability cases.

The Court primarily applied the principle that the Motor Vehicles Act, 1988, is a beneficial legislation, and compensation must be determined by law as it stands during the pendency of a matter.

It relied on Master Ayush v. Branch Manager, Reliance General Insurance Co. Ltd. [(2022) 7 SCC 738] and Hitesh Nagjibhai Patel v. Bababhai Nagjibhai Rabari [2025 INSC 1070], which established that compensation for a minor's permanent disability must be calculated based on the minimum wages of a "skilled worker" in the relevant State, rather than a mere global award.

It further applied New India Assurance Co. Ltd. v. Sonigra Juhi Uttamchand [(2025) 3 SCC 23], holding that unless a matter has attained finality, new principles of law enunciated by the Supreme Court apply to all pending proceedings.

The Court noted that the Impugned Award was passed in 2018 using the then-prevalent Master Mallikarjun "global compensation" standards.

However, since the appeal was pending, the Court held that the subsequent reinterpretation of the law—treating minors as potential skilled earners—must apply.

Applying the Karnataka State Notional Income for 2016 (₹9,500/month), the Court discarded the Tribunal's global award and recalculated loss of future income using the multiplier method (₹9,500 x 13% disability x 12 months x 18 multiplier = ₹2,66,760).

Furthermore, relying on the testimony of the Doctor (PW2) regarding the necessity of implant removal, the Court found the Tribunal erred in failing to award "Future Medical Expenses," and subsequently granted ₹40,000 for this head.

The total compensation was increased from ₹4,40,671 to ₹5,62,431. The Court ordered Respondent No. 2 (Insurance Company) to deposit the enhanced amount of ₹1,21,759 with 6% interest per annum within eight weeks. The appeal was allowed in part.