In a crucial ruling, the Supreme Court of India, comprising Justice Sanjay Karol and Justice Manmohan, underscored the value of skilled labour while determining compensation for accident victims. The Court held that a carpenter, by virtue of their profession, cannot be considered unskilled for the purpose of calculating motor accident compensation. This decision came while adjudicating the case of Karamjit Singh v. Amandeep Singh & Anr., highlighting the Court’s commitment to equitable compensation for victims of road accidents.
Case Background
The case originated from a motor vehicle accident on September 27, 2014, in Rupnagar, Punjab. Karamjit Singh, a carpenter, was riding his motorcycle with his son as a pillion rider when a collision with a vehicle driven by Amandeep Singh (Respondent No. 1) resulted in severe injuries to Singh. After extensive treatment, Singh’s right arm had to be amputated, drastically impairing his ability to earn a livelihood.
Singh initially approached the Motor Accident Claims Tribunal (MACT) for compensation, which awarded ₹6,84,582. On appeal, the Punjab and Haryana High Court enhanced the amount to ₹8,26,600. However, Singh sought further enhancement, arguing that the awarded compensation did not adequately reflect his earning potential and the impact of his disability.
Important Legal Issues
The key legal issues before the Supreme Court were:
1. Classification of Carpentry as Skilled Labour: Whether carpentry qualifies as skilled labour under the compensation framework for motor accident claims.
2. Assessment of Income: Determination of Singh’s monthly income for calculating loss of future earnings.
3. Adequacy of Compensation: Whether the enhanced compensation by the High Court adequately accounted for Singh’s permanent disability and loss of earning capacity.
Key Observations of the Court
Addressing the classification of carpentry as skilled labour, the bench observed:
“It would be unfair to classify a carpenter as an unskilled worker. Carpentry requires manual dexterity, craftsmanship, and a level of precision that only a trained professional can provide.”
Referring to precedents, including State of Orissa v. Adwait Charan Mohanty and Neeta v. Maharashtra State Road Transport Corporation, the Court emphasized that the skills inherent in carpentry distinguish it from unskilled work.
The Court also highlighted the necessity of fair compensation, stating:
“Justice demands that compensation in motor accident claims reflect the actual loss suffered by the victim, especially in cases involving skilled workers whose livelihood is directly impacted by disability.”
Decision of the Court
Based on the minimum wages for skilled labour in Punjab at the time of the accident, the Court recalculated Singh’s monthly income as ₹8,337.10. Considering the permanent disability of 74% and applying a multiplier of 14, the Court arrived at a revised compensation of ₹15,91,625. This amount included a 25% enhancement for future prospects in line with the principles established in National Insurance Company Ltd. v. Pranay Sethi.
The revised compensation was broken down as follows:
– Loss of Future Earnings: ₹10,36,467
– Future Prospects: ₹3,50,158
– Pain and Suffering: ₹60,000
– Medical Expenses: ₹60,000
– Other Expenses (Special Diet, Transportation, Attendant Charges): ₹70,000
The Court also increased the interest rate on the compensation from 6% to 7.5% per annum.
Case Details
– Case Title: Karamjit Singh v. Amandeep Singh & Anr.
– Case Number: Civil Appeal No. (Arising out of SLP (C) No. 27556 of 2023)
– Bench: Justice Sanjay Karol and Justice Manmohan
– Advocates for Appellant: Varun Mishra, Amit Kumar, Rochak Kharbanda, and others
– Advocates for Respondents: Anas Tanwir, Ebad Ur Rahman, Zainab Shaikh, and others
