Court holds that reassignment to lower job category due to accident-induced disability warrants compensation for loss of future income and remands case for reassessment.
In a significant judgment delivered on August 5, 2026, the Karnataka High Court (Kalaburagi Bench) addressed the issue of compensation under the Motor Vehicles Act, 1988, in the case of Chandrakanth v. Manzoor Ahmed and Ors. The Court underscored the principle that mere pay protection without regard to loss of future prospects and opportunities arising from a disability caused by an accident is insufficient.
The case concerned two claimants, Chandrakanth and Mahantesh, both employed as drivers (driver-cum-conductor and driver respectively) with the Transport Corporation. Both suffered injuries in a motor vehicle accident on April 16, 2016, which resulted in disabilities of 25% and 20% respectively. Post-accident, due to their disabilities, they were reassigned to the post of Attender, with pay protection intact.
Initially, the Motor Accident Claims Tribunal (MACT) awarded compensation focusing primarily on medical expenses, pain and suffering, and incidental expenses but did not award any compensation under the head of loss of future income. The Tribunal reasoned that since the claimants continued to receive the same salary, there was no actual loss of income, and hence, no compensation was due under that head.
On appeal, the High Court disagreed with the Tribunal's narrow interpretation. Justice K.V. Aravind observed that while the claimants' salaries were protected, the reassignment to a lower job category deprived them of future prospects, increments, perquisites, and career advancement opportunities inherent in their original skilled positions as drivers. The Court emphasized that loss of future income includes not only the current pay but also the loss of potential growth and benefits which the claimants could have enjoyed had they continued in their original roles.
The Court held that this reduction in job category constitutes a functional disability and warrants compensation. It assessed functional disability at 15% for both claimants for the purpose of compensation. However, since the Tribunal had not assessed the claimants' monthly income, the Court remanded the matter back to the Tribunal to reassess the loss of future income based on evidence from both parties.
Further, the High Court enhanced the compensation awarded under various heads, including attendant charges, food and nourishment, and conveyance expenses, recognizing the claimants' pain, suffering, and incurred expenses during hospitalization and treatment.
The revised compensation awarded by the Court amounts to Rs. 2,23,000/- for the claimant in MVC No. 02/2017 and Rs. 1,78,000/- for the claimant in MVC No. 01/2017. The Court directed the parties to appear before the Tribunal by September 29, 2026, for further proceedings and mandated that the Tribunal complete the reassessment within three months, citing the accident's occurrence in 2016.
This judgment is a crucial precedent affirming that compensation for motor vehicle accident victims must consider loss of future prospects and not merely immediate income loss, especially when victims are relegated to lower job categories due to disabilities sustained in accidents.
Bottom Line:
Motor Vehicle Accident - Compensation for loss of future income - Reduction in job category due to disability caused by accident, despite pay protection, warrants compensation for loss of future prospects and opportunities.
Statutory provision(s):
Motor Vehicles Act, 1988
Chandrakanth v. Manzoor Ahmed, (Karnataka)(Kalaburagi Bench) : Law Finder Doc Id # 2979243
