Facts: The appellant-claimant, a 30-year-old Manager at a private logistics firm, met with a head-on motorcycle accident on May 5, 2016, caused by the rash and negligent driving of the respondent-owner. The appellant sustained grievous injuries, including a fracture of the left femur, facial injuries, and a severe head injury. A Medical Board assessed his permanent physical disability at 63%, noting that the injuries resulted in partial blindness, cognitive impairment (IQ of 65, categorized as Mild Intellectual Disability), and restricted mobility. The Motor Accidents Claims Tribunal (MACT) accepted the 63% disability for calculating loss of earning capacity and awarded Rs.65,53,811/-. On appeal, the High Court reduced the functional disability to 30% and the total compensation to Rs.35,61,000/-, stating the MACT's assessment was on the higher side.
Procedural Posture: The case reached the Supreme Court via a Special Leave Petition filed by the appellant-claimant against the judgment of the High Court of Judicature at Madras, which had reduced the compensation awarded by the MACT, Coimbatore.
Issue: Whether the High Court was justified in reducing the functional disability from 63% to 30% without independent analysis of medical evidence, and whether the appellant’s actual functional disability should be reckoned at 100% given his neurological and cognitive impairments.
Holding: Yes, the High Court’s reduction was unjustified. The Supreme Court held that the appellant's functional disability deserves to be reckoned at 100% for the purpose of computing compensation.
Reasoning: The Court reasoned that the High Court interfered with the MACT’s findings of fact without a thorough reappreciation of evidence or assigning cogent reasons. Relying on "Raj Kumar v. Ajay Kumar", the Court emphasized that functional disability must reflect the actual loss of earning capacity relative to the victim's avocation. For a Manager, cognitive functions like memory, analytical ability, and communication are indispensable. The neuropsychological report indicated severe impairment of verbal and visual memory and frontal lobe dysfunction. These neurological sequelae, combined with partial blindness and orthopedic limitations, rendered the appellant totally incapable of performing managerial duties. Thus, despite a 63% physical disability, the "functional" impact was a total erosion of his earning faculties, justifying a 100% assessment.