Overlapping injury-compensation heads do not warrant reduction when the overall award remains reasonable.

On 13 November 2002, the claimant was walking on a road when a tractor driven by the third respondent allegedly struck him, causing crush injuries, fractures and permanent disability.

He claimed ₹9,00,000 in compensation, asserting that he was a daily wager earning ₹4,000 per month.

The Motor Accidents Claims Tribunal found the driver negligent and awarded ₹2,07,430 under several heads, including ₹74,000 for 74% permanent disability, ₹50,000 for loss of earning and ₹60,000 for injuries sustained.

The insurer appealed, challenging only the quantum and alleging overlap between compensation heads; it did not dispute negligence or liability.

Whether the Tribunal correctly assessed the compensation payable to the claimant

The appeal was brought under Section 173 of the Motor Vehicles Act, 1988.

The Court assessed whether the compensation awarded under the various heads was justified by the evidence and the claimant’s injuries, disability and treatment.

It applied the principle that some overlap between heads does not, by itself, require appellate interference where the total award is not excessive or unreasonable in the circumstances.

No precedent was cited.

The Court upheld the Tribunal’s award of ₹74,000 for 74% permanent disability, finding no reason to interfere with the rate of ₹1,000 per percentage of disability; it also observed that a higher rate would exceed the amount claimed under that head.

Although the Tribunal had not awarded future medical expenses despite the claim and medical evidence, and the Court considered the pain-and-suffering award of ₹10,000 inadequate, it found no justification to alter the overall compensation after considering the injuries, surgery and amounts awarded under the other heads.

The alleged overlap did not make the total award excessive or unreasonable.

It confirmed the award of ₹2,07,430 and directed the insurer to deposit the amount with accrued interest and costs, if not already deposited, within six weeks of receiving the judgment.

The claimant was permitted to withdraw the amount in accordance with the Tribunal’s order; there was no order as to costs.