These civil appeals arise from a devastating vehicular accident on April 10, 2011, involving a heavy goods vehicle and a motorcycle, which resulted in the instantaneous death of the driver, Sushant Prabhakaran, and severe, life-altering injuries—including total blindness and a permanent colostomy—to the pillion rider, Priyanka Das. The Supreme Court addressed critical questions regarding the correct multiplier based on the deceased’s age, the apportionment of compensation to a non-legally wedded partner, and the rigorous re-evaluation of functional disability versus physical impairment for an injured survivor working under corporate accommodations. The apex court dismissed the insurance company’s appeals while partially allowing the claimant’s appeal to enhance compensation to Rs. 3,77,84,297 based on a 100% whole-body permanent physical impairment certified by a multi-disciplinary medical board.
- Negligence and Standards of Proof: Motor Accident Claims Tribunal (MACT) proceedings are summary in nature, and negligence must be evaluated on the “preponderance of probabilities” rather than the strict criminal standard of “proof beyond reasonable doubt”.
- Multiplier Based on Deceased’s Age: Reaffirming established precedents including Sarla Verma, Pranay Sethi, Munna Lal Jain, and Sube Singh, the Court held that the multiplier must correspond to the age of the deceased bachelor (33 years, resulting in a multiplier of 16) rather than the ages of the dependents.
- Apportionment to Non-Spouse Dependents: Following principles in Manjuri Bera, the courts below acted correctly in providing a just apportionment of compensation to Priyanka Das as an injured claimant and recognized dependent despite the lack of formal documentary proof of a legal marriage.
- Functional vs. Physical Disability Assessment: Citing Pappu Deo Yadav, the assessment of permanent disablement must focus on the resulting loss of the claimant’s open-market income-generating capacity rather than mere retention in a specialized, highly accommodated corporate role.
- Medical Board Evaluation: Pursuant to the Supreme Court’s directives, a multi-disciplinary Medical Board at Safdarjung Hospital evaluated the claimant and certified a 100% Permanent Physical Impairment (PPI) affecting the whole body due to post-traumatic head injury, cortical blindness, pelvic fracture, and a permanent colostomy.
- Enhanced Final Compensation: The total compensation awarded to the injured claimant was revised and enhanced to Rs. 3,77,84,297 along with interest at 7.5% per annum, factoring in 100% functional disability, increased attendant charges for 24/7 care, future medical expenses, and loss of marriage prospects.
2026 INSC 950
Reliance General Insurance Company Limited v. Priyanka Das and Others (D.O.J. 03.09.2026)
