Motor accident compensation cannot be determined without assessing injuries and relevant evidence.

On 19 December 2007, the claimant was travelling in a rickshaw chhakda that overturned after its driver lost control, causing the claimant injuries.

The claimant sought compensation under Section 166 of the Motor Vehicles Act, 1988. The Motor Accident Claims Tribunal awarded Rs. 12,500, reasoning that the claimant had suffered no loss of income, but its judgment did not discuss the nature or extent of the injuries or assess the relevant evidence. The claimant appealed against that award.

Whether the Tribunal’s award could stand when it did not assess the claimant’s injuries or the relevant evidence on record.

Whether the matter should be remitted to the Tribunal for fresh consideration of the compensation claim.

A claim for compensation under Section 166 of the Motor Vehicles Act must be adjudicated on the evidence and result in just, fair and reasonable compensation.

The Court referred to Reliance General Insurance Company Limited v. Priyanka Das and Others, 2026 INSC 950, for the principle that functional disability cannot be reduced merely because the claimant remains in the same job or role, and to New India Assurance Company Limited v. Doli Satish Gandhi and Others, 2026 LiveLaw (SC) 504, for the principle that mediclaim reimbursement does not, by itself, bar a claim for treatment expenses.

It also cited Anishaben Sharifbhai Solanki and Others v. Sachinbhai Bharatbhai Suvagiya & Ors., 2025 SCC OnLine Gujarat 664, which cautioned against rejecting motor accident claims on a hyper-technical assessment that overlooks the evidence and the obligation to award just compensation.

The Tribunal’s award focused on the absence of loss of income but did not address the claimant’s injuries or demonstrate an assessment of the evidence relevant to compensation.

In view of that deficiency, and the principles requiring a fair, evidence-based assessment rather than undue emphasis on technicalities, the Court considered a fresh adjudication necessary. It remitted the claim rather than determining the amount of compensation itself.

The claim proceedings were restored to the Tribunal for fresh consideration in accordance with law, with both parties permitted to lead further evidence if advised. The Tribunal was directed to decide the claim within six months of receiving the order; the parties were directed to appear before it on 5 November 2026, and the Registry was directed to transmit the record and proceedings before that date.