Missing receipts do not bar reasonable incidental-expense compensation for an injured minor.

The four-year-old claimant sustained fractures of the right tibia and fibula in a motor-vehicle accident on 10 September 2020.

The Claims Tribunal awarded ₹20,000, comprising compensation for physical and mental suffering.

The claimant appealed under Section 173 of the Motor Vehicles Act, 1988, seeking enhancement, including compensation for his father’s lost income during treatment, transportation, attendant charges, special diet, and future treatment expenses.

The insurer opposed enhancement, noting the absence of documentary evidence of medical expenses.

Whether the compensation awarded for the claimant’s injuries should be enhanced to account for expenses and losses associated with his treatment, despite the absence of documentary proof of medical expenses.

Whether the enhanced compensation should carry interest, and at what rate and from what date.

The appeal was brought under Section 173 of the Motor Vehicles Act, 1988, which provides for an appeal from an award of a Claims Tribunal.

The Court applied the principle that compensation may account for reasonable miscellaneous out-of-pocket expenses arising from hospitalisation and treatment even where formal receipts are unavailable, having regard to the nature of the injuries and the circumstances shown by the record.

No precedent was cited.

The MLC and X-ray reports established fractures of the claimant’s right tibia and fibula.

Although the claimant had not produced documentary proof of medical expenses, the Court considered it reasonable to infer that a four-year-old with those injuries was unable to perform normal activities for about two months.

It also recognised that treatment and hospitalisation commonly entail miscellaneous expenses for which receipts may not be available.

The Court therefore added ₹20,000 for the father’s loss of income during treatment, transportation, attendant charges, and special diet, but made no separate award for future treatment expenses.

The additional ₹20,000 carries interest at 6% per annum from the date the claim application was filed until realisation; the remaining terms of the Tribunal’s award were left unchanged.

The Registry was directed to communicate the enhanced amount to the claimant in Hindi (Devanagari), with assistance from paralegal workers if required.