Supreme Court: Tribunal Cannot Reduce Expert’s Disability Assessment on “Mere Conjectures”

The Supreme Court of India has ruled that a Motor Accidents Claims Tribunal cannot arbitrarily reduce the percentage of disability assessed by a medical expert without providing “valid reasoning.” In a judgment delivered on July 14, 2025, a bench of Justice Sudhanshu Dhulia and Justice K. Vinod Chandran enhanced the compensation for a skilled mason injured in a road accident, accepting his claimed income and restoring the disability assessment made by the treating doctor. The Court increased the total compensation to ₹7,19,480.

The judgment arose from a civil appeal filed by Suresh Jatav, the claimant, challenging the quantum of compensation awarded by the lower courts for injuries he sustained in 2002.

Background of the Case

The case originates from a motor vehicle accident on August 12, 2002. The appellant, Suresh Jatav, was a passenger in an auto-rickshaw when it was struck by a bus being driven rashly and negligently. Mr. Jatav suffered severe injuries, including a compound fracture to the fibula of his right leg and a fracture to the ulna of his right hand. He was hospitalized for six days and underwent surgery on his leg.

In his claim before the Motor Accidents Claims Tribunal, Mr. Jatav asserted that he was a skilled mason earning ₹200 per day (approximately ₹6,000 per month) and had suffered a 100% functional disability. He presented evidence of his medical treatment and a co-worker testified to his income. The treating doctor assessed his permanent disability at 35%.

Decisions of the Tribunal and High Court

The Tribunal did not accept the appellant’s claimed income, instead assessing it at ₹3,000 per month. Crucially, the Tribunal reduced the disability assessment from 35% to 25%, reasoning that the 35% figure related only to the right leg and not the whole body. The Tribunal awarded a total compensation of ₹1,62,000.

The appellant then appealed to the High Court, which partially increased the award. The High Court raised the monthly income to ₹3,500, added a 40% enhancement for future prospects, and increased the amounts for special diet, pain and suffering, and other heads. However, the core grievances regarding the assessment of income and disability remained.

Supreme Court’s Analysis and Ruling

The Supreme Court, upon reviewing the case, found significant merit in the appellant’s arguments.

On the issue of disability assessment, the Court was critical of the Tribunal’s approach. Justice K. Vinod Chandran, writing the judgment, stated, “As far as disability is concerned, the doctor has assessed it at 35% and the Tribunal reduced it to 25% on mere conjectures. There should be valid reasoning to go behind the opinion of an expert, especially in the matter of assessment of disability.” The Court noted the doctor’s specific testimony that the appellant “was unable to sit down and walk and could not lift heavy weights” and was in “constant pain.” Given that the appellant was a skilled mason, the Court concluded, “The evidence of the doctor would indicate that he could not have continued his chosen vocation.” Consequently, the Court held that his disability must be assessed at 35%.

Regarding the appellant’s income, the Court found the claim of ₹6,000 per month to be credible. It referred to the precedent set in Ramachandrappa v. Manager, Royal Sundaram Alliance Insurance Company, where the income of a Coolie in 2004 was determined to be ₹4,500 per month. The Court observed that a skilled mason’s income would be higher and thus accepted the claimed amount.

Based on this analysis, the Supreme Court recalculated the compensation. The final award was structured as follows:

The Court directed the insurance company to pay the total amount, less any sums already paid, with interest as determined by the Tribunal, within two months from the date of the judgment. The appeal was allowed in these terms.