Notional income for engineering students must reflect potential professional earnings rather than minimum wages for unskilled workers.

On December 4, 2010, the appellant, a third-year B-Tech student, was injured when his motorcycle was hit by a Santro car driven rashly and negligently by Respondent No. 1

An FIR was registered under Sections 279/338 of the IPC

The Motor Accident Claims Tribunal (MACT), via an award dated April 3, 2013, granted compensation of Rs. 6,19,386/- but rejected the claim for ‘loss of income’ as the appellant was a student

Subsequently, the Disability Board of Dr. Baba Saheb Ambedkar Hospital certified the appellant with a 29% physical impairment of the left lower limb

The appellant sought enhancement of the award specifically regarding ‘loss of future earning capacity’

1. Whether the notional income of an engineering student should be assessed for calculating loss of future earning capacity despite not being employed at the time of the accident

2. Whether the physical disability of 29% in the lower limb warrants a specific assessment of functional disability to determine future loss of earnings

The court relied on S. Mohammed Hakkim v. National Insurance Co. Ltd & Ors. (2025:INSC:905) and Navjot Singh v. Harpreet Singh (2020), which established that the notional income of a degree-course engineering student should not be equated to that of an unskilled worker and should be fixed at a minimum of Rs. 20,000/- per month

The court applied the multiplier method from Sarla Verma v. DTC (2009) and the standards for ‘future prospects’ (40%) from National Insurance Co. Ltd. v. Pranay Sethi (2017)

Furthermore, the court applied the principles of Raj Kumar v. Ajay Kumar & Anr. (2011) to assess functional disability relative to the physical impairment for the purpose of compensation

The court observed that the appellant’s status as a 3rd-year engineering student at a premier institute indicated a bright future, and his lower limb impairment would reasonably impact his technical career requiring mobility

Following the S. Mohammed Hakkim precedent, the court fixed his notional income at Rs. 20,000/- per month

To this, a 40% addition for future prospects was made, and a multiplier of 17 was applied based on the appellant's age

While the physical impairment was 29%, the court assessed the functional disability at 20% for the computation of loss of future income

The court further determined that previously awarded amounts for ‘loss of fees’ and ‘studies’ should be subsumed into a broader head of ‘loss of amenities of life’, awarded at Rs. 1,00,000/-

The court held that the enhanced amount of Rs. 11,63,900/- shall carry interest at 9% per annum from the date of the disability assessment (April 22, 2014)

The court directed the insurer to deposit the amount with the MACT within six weeks, with specific directions for the immediate release of Rs. 5,00,000/- to the claimant and the remainder to be placed in phased Fixed Deposit Receipts (FDRs) of Rs. 25,000/- each to ensure financial security