In a significant verdict on motor accident compensation and disability assessment, a Supreme Court bench comprising Justice S.V.N. Bhatti and Justice N.V. Anjaria held that the calculation of functional disability must be assessed on an injured victim’s earning capacity in the open, competitive market rather than on their retention in a role sustained by corporate compassion and specialized accommodations. Delivering two connected judgments on Thursday, the apex court enhanced the compensation awarded to an injured corporate executive suffering from 100 percent permanent impairment to Rs 3,77,84,297 while dismissing the insurer’s challenge. In a related appeal concerning the fatal accident of the motorcycle rider in the same crash, the bench upheld the compensation of Rs 82,56,152 awarded to the deceased’s parents, ruling that the multiplier must be determined based on the age of the deceased and affirming that the co-rider could not be recognized as his legally wedded wife in the absence of documentary proof.
Background of the Case
The appeals arose out of a road traffic accident that occurred on April 10, 2011, at around 5:30 PM near the Brijghat Bridge. A motorcycle driven by 33-year-old Sushant Prabhakaran, with 35-year-old Priyanka Das as the pillion rider, was struck by a heavy goods vehicle bearing registration number HR-55-2812. The truck ran over Sushant Prabhakaran, causing his instantaneous death, while Priyanka Das suffered catastrophic, life-altering injuries across multiple vital parts of her body. An FIR (No. 198) was registered at Police Station Gadmukteshwar on the complaint of a passerby, Radhe Shyam Kaushik.
Following the accident, Priyanka Das filed two separate claim petitions before the Motor Accident Claims Tribunal (MACT), Gurugram: MACT Petition No. 9 of 2014, claiming Rs 5 crore for the death of Sushant Prabhakaran (pleading she was his widow), and MACT Petition No. 94 of 2014, claiming Rs 12 crore for her own grievous personal injuries.
At the time of his demise, Sushant Prabhakaran was employed as Contact Centre Manager at Ericsson India Private Limited with an annual gross salary of Rs 10,65,600. Priyanka Das was employed as a Deputy Group Manager at IBM Daksh (Concentrix Daksh Services India Pvt. Ltd.) in Cyber City, Gurgaon.
Proceedings Before the Tribunal and High Court
On April 3, 2017, the Tribunal fastened joint and several liability on the truck driver, owner, and insurer, Reliance General Insurance Company Limited. The Tribunal rejected the insurer’s argument regarding the lack of a valid fitness certificate after examining the vehicle’s registration certificate.
In the death claim petition, the Tribunal found no documentary evidence proving Priyanka Das was the legally wedded wife of the deceased, noting that she had listed him as her fiancé in employment records. Assessing the net annual dependency loss at Rs 6,70,575, adding 50 percent towards future prospects, deducting 50 percent for personal expenses, applying a multiplier of 16 based on the deceased’s age (33 years), and deducting sums received under a personal accidental policy, the Tribunal awarded Rs 82,56,152. Out of this, Rs 77,06,152 was apportioned to the deceased’s mother Sandhya Prasad, Rs 50,000 to his father Sahadeov Prasad, and Rs 5,00,000 to Priyanka Das. On appeal, the Punjab and Haryana High Court upheld the award and only modified Das’s apportionment to Rs 7,50,000.
In the injury claim petition, the medical records confirmed that Das suffered pelvic fractures, severe degloving injuries to the perineal region, third-degree friction burns to the gluteal region, incurable 100 percent blindness due to traumatic bilateral occipital gliosis, and a failed bowel restoration at AIIMS necessitating a permanent colostomy stoma for life. However, because she continued working through assistive software and saw her Cost to Company (CTC) rise from Rs 16 lakh to Rs 19 lakh, the Tribunal assessed her functional disability at 60 percent, awarding Rs 1,35,53,298. On appeal, the High Court enhanced her functional disability to 80 percent and awarded Rs 2,94,82,617, relying on the apex court ruling in Pappu Deo Yadav v. Naresh Kumar & Ors. to grant 50 percent future prospects.
Both Reliance General Insurance and Priyanka Das approached the Supreme Court against the High Court’s verdicts.
Arguments Before the Supreme Court
In the fatal injury appeals, Reliance General Insurance contended that the multiplier applied must correspond to the age of the deceased’s parents rather than the deceased. In response, counsel for the respondents argued that the issue was no longer res integra and stood conclusively settled by binding precedents. On the cross-appeal, senior advocate Prashanto Chandra Sen, appearing for Das, argued that her apportionment ought to be enhanced under the principles of the Manjuri Bera judgment.
In the personal injury appeals, the insurer argued that there was no loss of earning capacity or functional disability because Das retained her employment as Deputy Group Manager and received salary increments. The insurer also challenged the grant of future prospects, the award of attendant charges without receipts, and the medical expense heads.
Conversely, counsel for Das contended that her capacity to work in an open competitive environment had been completely extinguished. Citing an independent Medical Board report directed by the Supreme Court on October 17, 2025—which was constituted at Vardhman Mahavir Medical College & Safdarjung Hospital—Das’s counsel emphasized that the board had officially assessed her with 100 percent Permanent Physical Impairment (PPI) of the whole body.
The Supreme Court’s Analysis
Addressing the standard of proof and negligence, the Supreme Court reaffirmed that MACT proceedings are summary in nature, where negligence is evaluated on a preponderance of probabilities rather than proof beyond reasonable doubt. The bench observed that the registration of the FIR and chargesheet against the truck driver discharged the primary onus.
On the challenge to the multiplier in the fatal accident case, the bench affirmed the rulings of the Tribunal and High Court, reiterating the principles established in Sarla Verma v. Delhi Transport Corporation, Munna Lal Jain v. Vipin Kumar Sharma, National Insurance Co. Ltd. v. Pranay Sethi, and Sube Singh v. Shyam Singh. Justice Bhatti wrote:
“Addressing the specific legal question of which multiplier method would apply to the bachelors, a Three-Judge Bench of this Court in Munna Lal Jain (supra) held that the multiplier must be determined by the age of the deceased, not by the age of the dependents. This was later confirmed by a subsequent ruling of this Court in Sube Singh (supra), which held that this rule is no longer res integra.”
Consequently, applying a multiplier of 16 for the deceased’s age bracket of 31 to 35 was held to be correct. On Das’s claim as the wife, the bench held:
“The Tribunal and the High Court have appreciated the oral and documentary evidence pleaded to confirm the finding of fact that Priyanka Das was not his legally wedded wife. We are not reappreciating the evidence to record a different finding, nor to express our concurrence with the view taken by the Tribunal and the High Court.”
Turning to the personal injury appeal and the insurer’s argument that Das suffered no actual loss of earning capacity, the bench rejected the insurer’s objections in light of the Safdarjung Hospital Medical Board report. Ruling on the assessment of disability for white-collar workers accommodated by employers, the court held:
“The calculation of functional disability depends on assessing the victim’s earning capacity in the open, competitive market, rather than on retention in a specific, highly accommodated role.”
The bench noted that Das had lost out on career progressions—such as promotions to General Manager, Director, or Vice President—and worked only because of extreme accommodations:
“The record further indicates that she is able to perform her current duties only through specially created software, flexible working hours, and extreme accommodations provided by her employer as an act of corporate compassion.”
The court held:
“Based on the official Medical Board Report issued by Vardhman Mahavir Medical College & Safdarjung Hospital, which evaluated the Claimant and certified a 100% PPI of the whole body due to post-traumatic head injury with cortical blindness, pelvic fracture, and a permanent colostomy, the compensation calculation shifts from the High Court’s 80% assessment to a 100% functional disability because the Claimant’s capacity to independently secure, sustain, or advance employment in the open labour market has been entirely extinguished.”
The Decision
In the appeals arising from the demise of Sushant Prabhakaran (Civil Appeal Nos. 12085 and 12086 of 2026), the Supreme Court dismissed both the appeals filed by the insurer and Priyanka Das, maintaining the High Court’s apportionment and the total compensation of Rs 82,56,152.
In the appeals concerning Priyanka Das’s injuries (Civil Appeal Nos. 12087-12088 of 2026 and 12089 of 2026), the Supreme Court dismissed the insurer’s appeals and partly allowed the claimant’s appeal. Re-calculating the loss of future earning capacity at 100 percent disability with 50 percent future prospects (Rs 2,42,08,416), attendant charges for three attendants for 24×7 care (Rs 28,80,000), Rs 20,00,000 for loss of marriage prospects, Rs 15,00,000 for pain and suffering, and other admissible heads, the bench enhanced the total compensation payable to Priyanka Das to Rs 3,77,84,297 with 7.5 percent interest per annum from the date of the claim petition until realization.
Case Title: Reliance General Insurance Company Limited v. Priyanka Das and Others (with connected appeals)
Case No.: Civil Appeal No. 12085 of 2026 with Civil Appeal No. 12086 of 2026; Civil Appeal Nos. 12087-12088 of 2026 with Civil Appeal No. 12089 of 2026
Bench: Justice S.V.N. Bhatti and Justice N.V. Anjaria
Date: September 3, 2026
