Even If Not Claimed, Courts Must Award Just Compensation: Andhra Pradesh High Court Enhances Injury Award by Over 200% in Accident Case

“There is no restriction that the Tribunal/Court cannot award compensation amount exceeding the claimed amount”— Andhra Pradesh High Court  significantly enhanced the compensation awarded to an injured claimant from ₹66,000 to ₹2,11,880, stressing that “courts are duty-bound to award just compensation, even if it exceeds the amount claimed.”

Justice A. Hari Haranadha Sarma, while allowing the Motor Accident Civil Miscellaneous Appeal No. 2382 of 2015, held that the Motor Vehicles Act is a benevolent legislation, and compensation cannot be mechanically determined or unjustly restricted by the amount originally prayed for.

"Crush Injury With 30% Disability to a Coolie Cannot Be Valued at Just ₹66,000—Tribunal Must Apply Socioeconomic Lens"

The case stemmed from a road accident that took place on 28th December 2009 at Thippaluru bridge, Kadapa Road, involving a lorry bearing No. AP 24 V 5416. The injured appellant, Kovvuri Eswaramma, a 29-year-old coolie, suffered multiple injuries, including a fracture of the second metatarsal in her left foot.

Despite permanent disability being assessed at 30% by the District Medical Board, the Motor Accident Claims Tribunal (MACT), Kadapa, had awarded only ₹30,000 towards disability and a total of ₹66,000 under all heads, prompting the appeal.

Criticizing the MACT's approach, the High Court observed: “The learned MACT failed to consider the Disability Certificate vide Ex.A4, issued by the competent District Medical Board… There are no grounds to completely ignore the disability as spoken by the doctor.”

“Multiplier Method Is Not Only for Death Claims—It Applies to Injury Cases Too Where Earning Capacity Is Affected”

The High Court adopted a structured and economic rationale for quantification. Referring to Supreme Court rulings in Rajkumar v. Ajay Kumar and Sidram v. United India Insurance Co., it applied the multiplier method to compute the loss of future income.

The injured, earning approximately ₹2,400/month (based on ₹80/day for an unskilled labourer in 2009), was held to have lost income equivalent to ₹8,640 per annum due to 30% disability. Applying a multiplier of 17 (based on her age of 29), the Court arrived at a figure of ₹1,46,880 for permanent disability alone, nearly five times more than what MACT awarded.

“Pain, Suffering, and Attendant Charges Must Be Judged Humanely, Not Mechanically”

Justice Sarma further corrected the lower tribunal’s omission to award compensation under heads like loss of income during treatment, attendant charges, and loss of amenities. The revised breakdown by the High Court was as follows:

• Pain and Suffering: ₹25,000

• Transportation: ₹5,000

• Extra Nourishment: ₹5,000

• Loss of Income During Treatment: ₹10,000

• Medical Expenses: ₹10,000

• Permanent Disability: ₹1,46,880

• Attendant Charges: ₹5,000

• Loss of Amenities: ₹5,000

• Total: ₹2,11,880

“Even Unclaimed Reliefs Can Be Granted If Justified—Motor Vehicles Act Is a Welfare Law”

Citing Nagappa v. Gurudayal Singh, Kajal v. Jagdish Chand, and Ramla v. National Insurance Co., the Court held:

“There is no restriction that the Court cannot award compensation exceeding the claimed amount… Just compensation cannot be time-barred, and no new cause of action is required to enhance the amount.”

Justice Sarma emphasized that the primary duty of courts under Section 168 of the Motor Vehicles Act is to ensure justice, not procedural rigidity.

“The intention behind grant of compensation is to put back the injured party, as far as possible, in the same position as if the injury had not taken place.”

The High Court allowed the appeal and passed the following directions:

• The compensation is enhanced to ₹2,11,880 with 6% interest per annum from the date of petition till realization.

• The claimant is permitted to withdraw the amount upon deposit.

• Respondents (owner and insurer) were directed to deposit the balance within two months.

• The claimant shall pay court fee only for the enhanced portion.

Justice Sarma concluded: “In the matter of computation of compensation, the approach must be more broad-based than in the assessment of damages… sympathy must be balanced with objectivity.”

Date of Decision: 30th August 2025