In a significant ruling, the Supreme Court of India has held that a Motor Accident Claims Tribunal (MACT) cannot disregard the findings of a duly constituted Medical Board while determining compensation for accident victims. The judgment, delivered in Prakash Chand Sharma v. Rambabu Saini & Anr., significantly enhanced the compensation for the appellant, who was left in a comatose state after a road accident.
A bench comprising Justice Sanjay Karol and Justice Manmohan ruled in favor of the victim, increasing his compensation from ₹19.39 lakh, as determined by the Rajasthan High Court, to ₹48.7 lakh with 7% interest per annum. The Court emphasized that the Medical Board’s findings must be given due weight and cannot be substituted by a Tribunal’s personal assessment.
Background of the Case
The case arose from a tragic road accident on March 23, 2014, when Prakash Chand Sharma was hit by a rashly driven Maruti Omni (RJ 02 UA 1663) while riding his motorcycle in Alwar, Rajasthan. The accident left him with severe head and leg injuries, ultimately rendering him comatose. An FIR (No. 81/14) was registered at Tehla Police Station, and Sharma was initially treated at Katta Hospital, Bandikui, before being transferred to Sawai Mansingh Hospital, Jaipur.
His family filed a compensation claim (Claim No. 575/2014) before the MACT, Alwar, which awarded ₹16.29 lakh as compensation. Dissatisfied with the Tribunal’s assessment, Sharma’s family appealed to the Rajasthan High Court, Jaipur Bench, which partly allowed the appeal and enhanced the amount to ₹19.39 lakh. However, the High Court refused to accept the Medical Board’s 100% disability assessment and instead fixed disability at 50%, significantly reducing the compensation.
Still aggrieved, Sharma’s family moved the Supreme Court challenging the reduced disability assessment and the denial of compensation for attendant charges and future prospects.
Key Legal Issues Considered
- Negligence and Liability – The Tribunal confirmed that the accident occurred due to the negligence of the Maruti Omni driver, and the insurance company was liable to pay the compensation.
- Extent of Disability – The Tribunal and High Court ignored the Medical Board’s certification of 100% disability and arbitrarily fixed it at 50%.
- Attendant Charges & Future Prospects – The High Court refused to grant attendant expenses and did not account for loss of future prospects in calculating compensation.
Supreme Court’s Observations and Verdict
The Supreme Court came down heavily on the Tribunal’s disregard of expert medical opinion, ruling that a Tribunal cannot unilaterally assess disability when a duly constituted Medical Board has given a clear opinion.
“The Tribunal questioned the competence of the Medical Board to assess the permanent disability of the claimant-appellant. If it had reason to doubt the medical certificate, the option available before it was to have the disability re-assessed, but it could not have gone into the details of the determination of disability.”
The Court noted that the Medical Board’s report explicitly stated that the appellant had no speech, no intellectual functions, could not stand or walk, and required a catheter. Based on these findings, the Supreme Court ruled that the 100% disability assessment was justified.
Enhanced Compensation Breakdown
| Head of Compensation | Tribunal Award (₹) | High Court Award (₹) | Supreme Court Award (₹) |
| Loss of Future Income | 12,39,810 | 12,39,810 | 24,79,620 |
| Future Prospects (25%) | — | 3,09,953 | 6,19,905 |
| Attendant Charges | — | — | 7,80,000 |
| Medical Expenses | 1,71,155 | 1,71,155 | 1,71,155 |
| Hospitalization Expenses (37 Days) | 18,500 | 18,500 | 18,500 |
| Physical & Mental Agony | 2,00,000 | 2,00,000 | 2,00,000 |
| Pain & Suffering | — | — | 6,00,000 |
| Total Compensation | 16,29,465 | 19,39,418 | 48,70,000 |
The Supreme Court rounded off the final amount to ₹48.7 lakh and directed that interest at 7% per annum be paid from the date of the claim petition.
