MP HC Raises Fatal-Accident Compensation To Rs 6.73 Lakh, Adding Rs 50,000 For Treatment Despite Rejecting Medical Bills

Deceased Lalaram died on 11 April 2024 from injuries sustained when a car allegedly driven negligently struck him.

His claimants sought compensation under Section 166 of the Motor Vehicles Act, 1988.

The Claims Tribunal awarded Rs. 5,58,020, including Rs. 50,000 for medical expenses, and assessed Lalaram’s monthly income at Rs. 8,200.

The claimants appealed for enhancement, contending that the applicable monthly minimum wage was Rs. 9,825 and that their medical bills had been wrongly rejected.

They also sought condonation of a 98-day delay; the Court allowed that application in the absence of written objection.

Section 173(1) of the Motor Vehicles Act, 1988 provides for an appeal against an award of a Claims Tribunal; the claim itself was brought under Section 166

The Court applied the MPSLSA minimum-wage guideline for an unskilled worker on the accident date in assessing income at Rs. 9,825 per month

It retained the Tribunal’s multiplier of 5 and one-third deduction for personal and living expenses

The Court did not rely on the Bombay High Court decision cited by the claimants; it independently assessed the evidentiary deficiencies and the amount appropriate for medical expenses

The Court accepted that the Tribunal had treated Lalaram as an unskilled worker and found that the applicable monthly income should have been Rs. 9,825, not Rs. 8,200

It upheld the rejection of the medical bills because the hospital records and prescriptions did not sufficiently establish the connection between the medicines purchased and Lalaram’s treatment; it also found that Exhibit P-168 related to another injured person, not Lalaram

Nevertheless, given the duration and circumstances of Lalaram’s treatment, the Court awarded an additional lump sum of Rs. 50,000 for medical expenses, expressly without treating the disputed bills as proved

Applying the retained multiplier and deduction, it calculated total compensation of Rs. 6,73,000

The enhanced amount carries interest at 6% per annum from the date the claim petition was filed until realization, subject to adjustment for amounts already paid or deposited

the remaining findings and directions were left undisturbed.