A motor accident claimant who sustained grievous injuries — including a severe head injury, facial injuries, and left femur fracture — in a 2016 head-on motorcycle collision approached the Supreme Court by special leave after the Madras High Court slashed his MACT-awarded compensation from Rs.65,53,811/- to Rs.35,61,000/- by unilaterally reducing the assessed functional disability from 63% to 30%.
The Supreme Court allowed the appeal and enhanced total compensation to Rs.97,73,011/- at 7.5% p.a. interest from the date of the claim petition. The Court found that the High Court had reduced the functional disability figure without undertaking any independent reappreciation of the uncontroverted Medical Board certificate or the neuropsychological assessment report, and without assigning cogent reasons — a course impermissible under the Motor Vehicles Act, 1988, a beneficial and welfare-oriented legislation. Applying the three-step framework from Raj Kumar v. Ajay Kumar [(2011) 1 SCC 343], the Court evaluated the cumulative effect of the claimant's partial blindness, orthopedic limitations, severe verbal and visual memory impairment, frontal lobe dysfunction, and an IQ score of 65 (Mild Intellectual Disability). It held that these impairments struck at the core competencies indispensable for managerial work and assessed functional disability at 100% for the purpose of computing loss of earning capacity — higher even than the MACT's 63%.
The Court reiterated that an appellate court interfering with a MACT's findings on disability and loss of earning capacity must undertake a thorough reappreciation of evidence and assign cogent, clear, and convincing reasons. Absent contra evidence from the insurer, a bare assertion that physical disability cannot be "mechanically" equated with functional disability does not justify a downward revision. The respondent-insurer was directed to deposit the balance compensation within six weeks before the MACT, Coimbatore, with liberty to recover from the driver-owner.