Facts
The appellant was 13 years old when he sustained pelvic and urethral injuries in a motor accident.
Source reference: p. 2Although the pelvic fracture left no residual disability, the urethral injury required daily self-catheterisation and dilation; the Medical Board could not quantify the resulting disability as a percentage.
Source reference: pp. 2–3, paras. 4–5The MACT awarded ₹15,88,008, including ₹3,00,000 for loss of future income and ₹10,80,000 for catheterisation costs, calculated using a multiplier of 15.
Source reference: pp. 1, 4, para. 11The claimant appealed, seeking enhancement on both heads.
Source reference: p. 1, para. 2Issues
1. Whether the claimant’s loss of future income should be reassessed by applying a functional-disability percentage, skilled-worker minimum wages, future prospects, and a multiplier appropriate to a minor.
Source reference: pp. 1–2, para. 2(i)2. Whether the compensation for the claimant’s continuing catheterisation expenses should be calculated using a multiplier of 18 rather than 15.
Source reference: p. 2, para. 2(ii); p. 4, para. 11Law Applied
The Court relied on Rubi Devi & Anr. v. The New India Assurance Co. Ltd. & Ors., 2026:DHC:3674, in taking the multiplier applicable to a minor as 18.
Source reference: p. 3, para. 8For assessing future loss of income, the Court applied skilled-worker minimum wages of ₹4,358 per month, added 40% towards future prospects, and assessed functional disability at 70%.
Source reference: p. 3, paras. 6–7It also applied a multiplier of 18 to the claimant’s recurring catheterisation costs.
Source reference: p. 4, para. 12No statute is expressly identified in the judgment.
Source reference: no citationReasoning
The Court considered the continuing, daily management required by the urethral injury and the medical evidence that the claimant could not meet the physical standards for Army or paramilitary jobs.
Source reference: pp. 2–3, paras. 4–6It concluded that the condition would affect his future employment prospects and career, and assessed functional disability at 70%, notwithstanding the absence of a quantified medical percentage.
Source reference: pp. 2–3, paras. 4–6It then recalculated future-income compensation using skilled-worker minimum wages, 40% future prospects, and a multiplier of 18; it also allowed seven months’ income loss for the treatment period.
Source reference: p. 3, paras. 7–9Because catheterisation was required daily and the claimant was 13 at the time of the accident, the Court increased the multiplier for that expense from 15 to 18.
Source reference: p. 4, paras. 11–12Holding
The Court enhanced the total compensation from ₹15,88,008 to ₹24,56,985, an increase of ₹8,68,977, with interest at 7.5% per annum.
The Insurance Company was directed to deposit the enhanced amount, with accrued interest, before the MACT within four weeks; the entire compensation was to be released as a lump sum into the claimant’s designated savings account.
Source reference: p. 5, para. 15The appeal was disposed of.
Source reference: p. 6, para. 16Original Court PDF
Rahul JangidvsCholamandlam Insurance Company Ltd & Anr
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