The Gujarat High Court has emphasised that when determining compensation in a motor accident claim, it is not enough to mechanically accept a disability certificate’s percentage figure. Instead, the victim’s functional disability — how the injury affects the ability to work and earn — must be evaluated on the facts of the case before awarding compensation under the Motor Vehicles Act.
Court’s Reasoning
The Court noted that not all physical injuries necessarily translate into a loss of earning capacity; the impact depends on the nature of the injury and the claimant’s occupation.
Live Law
In the case before it, a Motor Accident Claims Tribunal had accepted a disability certificate showing 47% disability for a cashier involved in a road accident without giving any reasons, even though a medical board had assessed disability at 27%. The High Court said such a mechanical approach was improper and that the tribunal failed to consider functional disability in context of the claimant’s work.
The Court held that loss of earning capacity must be tied to the actual impact of the disability on the claimant’s ability to perform their job rather than just the numerical percentage noted in the certificate.
Significance
This judgment reinforces that in motor accident compensation proceedings, authorities must evaluate how an injury affects a person’s real-world ability to earn and function in their specific profession. Medical disability percentages alone — without analysis of functional impact — are not enough to determine fair damages under the law
