Nominal compensation may be awarded for simple accident injuries despite absence of MLC or treatment bills.

Both appeals arose from the same motor-vehicle accident dated 08.02.2025 and were decided by a common order.

In MAC No. 1282 of 2026, Suresh Kumar Dewangan challenged the award dated 06.03.2026 of the Additional Motor Accident Claims Tribunal, Durg, which granted Rs. 15,350 towards repair of his motorcycle but awarded no compensation for the simple injuries allegedly sustained by him.

In MAC No. 1276 of 2026, the claimants sought enhancement of the compensation awarded for the death of Sushila Bai Dewangan, aged approximately 46 years.

The Tribunal had awarded Rs. 17,53,095 towards loss of dependency and conventional heads, including funeral expenses, loss of estate and consortium.

The insurer opposed both appeals, contending that the Tribunal had awarded just and proper compensation.

Whether Suresh Kumar Dewangan was entitled to additional compensation for the simple injuries allegedly suffered in the accident, despite the absence of an MLC report and treatment bills?

Whether the compensation of Rs. 17,53,095 awarded for the death of Sushila Bai Dewangan required enhancement?

The appeals were considered under Section 173 of the Motor Vehicles Act, 1988, which permits an appeal against an award of a Motor Accident Claims Tribunal.

Compensation must be just and reasonable and is to be assessed on the basis of the evidence and applicable principles governing loss of dependency and conventional heads.

For the fatal-accident claim, the Court relied on National Insurance Co. Ltd. v. Pranay Sethi, (2017) 16 SCC 680, concerning addition for future prospects and conventional heads; Sarla Verma v. Delhi Transport Corporation, (2009) 6 SCC 121, concerning computation of loss of dependency; and Magma General Insurance Co. Ltd. v. Nanu Ram, (2018) 18 SCC 130, concerning consortium payable to eligible family members.

Where simple injuries are established but medical evidence and treatment bills are absent, a reasonable lump-sum amount may be awarded on the facts of the case.

With respect to MAC No. 1282 of 2026, the Court accepted that Suresh Kumar Dewangan had sustained simple injuries but noted that no MLC report or treatment bills had been produced.

In the absence of detailed medical evidence, it considered Rs. 2,000 to be a just and reasonable lump-sum amount for the injuries.

The existing award of Rs. 15,350 for motorcycle repairs was therefore enhanced to Rs. 17,350.

Regarding the death claim, the Court found that the Tribunal had correctly applied the principles governing loss of dependency, funeral expenses, loss of estate and consortium under Pranay Sethi, Sarla Verma and Magma General Insurance.

Since the assessment was consistent with those principles, no basis for further enhancement was established.

MAC No. 1282 of 2026 was partly allowed: the compensation awarded to Suresh Kumar Dewangan was enhanced from Rs. 15,350 to Rs. 17,350, granting him an additional Rs. 2,000 for simple injuries.

The additional amount was directed to carry interest at 6% per annum from the date of filing of the claim application until realization; the remaining terms of the Tribunal’s award were left undisturbed.

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