Motor accident compensation must include 25% future prospects for injured claimants aged forty to fifty.

On March 2, 2022, the appellant was traveling on a motorcycle when a car driven at excessive speed dashed into him, causing grievous injuries

The Motor Accident Claims Tribunal (Main), Kachchh at Bhuj, awarded the appellant ₹2,13,000/- with 7% interest per annum in MACP No. 106 of 2022

The appellant challenged this award on the grounds of quantum, specifically arguing that the Tribunal failed to consider future prospects, awarded inadequate compensation for pain and suffering, and neglected medical expenses

1. Whether the appellant is entitled to a 25% addition to his monthly income for "future prospects" despite having survived the accident

2. Whether the compensation awarded under the heads of pain, shock, and suffering, and medical expenses was just and adequate

The Court applied the principles of "just compensation" under the Motor Vehicles Act, 1988.

It relied on the landmark precedents of National Insurance Company Ltd. v. Pranay Sethi and Ors. (2017) and Sidram v. Divisional Manager, United India Insurance Company Limited and Anr. (2023), which mandate the addition of future prospects (25% for individuals aged 40–50) to the assessed income in personal injury cases involving functional disability

The Court noted that the appellant was 47 years old with a 13% functional disability

While the Tribunal correctly assessed the base income at ₹8,900/- per month based on minimum wages, it erred by not applying future prospects

Applying Pranay Sethi, the Court added 25% to the income (totaling ₹11,125/-) and recalculated the future loss of income using a multiplier of 13, totaling ₹2,25,576/-

Regarding non-pecuniary damages, the Court found the previous award for "pain, shock, and suffering" inadequate given the fracture and 22% limb disability, enhancing it from ₹7,000/- to ₹15,000/-

Finally, it addressed the complete omission of medical expenses by awarding a lump sum of ₹10,000/- based on the treatment period

The appellant is held entitled to an additional amount of ₹63,576/- with interest at 7% per annum from the date of the claim petition until realization. The Insurance Company was directed to deposit the enhanced amount within six weeks