The Supreme Court, in Oriental Insurance Co Ltd v. Kalu Ram (2026) INSC 653, held that the Motor Vehicles Act, 1988 is beneficial legislation and courts are duty-bound to award 'just compensation' even if a conventional head such as filial consortium has been overlooked by the Claims Tribunal and the High Court. The Court observed that the parents of an unmarried deceased son are entitled to compensation under the head of filial consortium, and enhanced the compensation by Rs. 40,000 each for both parents, amounting to a total increase of Rs. 80,000. The Bench reiterated that it does not ordinarily interfere with concurrent findings of fact by the Tribunal and High Court unless such findings are perverse, manifestly erroneous, or based on no evidence, relying on precedents such as National Insurance Company Limited vs. Pranay Sethi and Others ((2017) 16 SCC 680) and Magma General Insurance Company Limited vs. Nanu Ram alias Chuhru Ram and Others ((2018) 18 SCC 130).
In the same case, the Court dealt with a claim arising from a collision where a Wagon-R car hit a stationary truck parked in the middle of the road at 3:00 a.m. without parking lights, indicators, reflectors, or warning signs. The truck driver and owner did not testify to support their claim of a tyre puncture. The Supreme Court held that while a rear-end collision does not automatically imply negligence or contributory negligence on the part of the following vehicle, a stationary vehicle left unattended on a public road in the dead of night without any warning signals constitutes an evident hazard. In the absence of evidence from the truck driver, the adverse inference drawn by the Tribunal regarding negligence was justified. The Court concluded that the proximate cause of the accident was the negligent act of leaving the vehicle unattended on the road without taking precautionary measures.
Another aspect of the judgment pertained to the assessment of future prospects for a 20-year-old bachelor who was pursuing the final year of Chartered Accountancy and undergoing articleship at the time of his death. The Tribunal had departed from the actual stipend income and assessed his monthly income at Rs. 55,500 by factoring in his educational progression, professional trajectory, and imminent entry into the CA profession. The Supreme Court upheld this approach, holding that while compensation cannot be based on pure speculation or unrelated salary benchmarks, the determination of 'just compensation' does not require mathematical exactitude. The Court found that the Tribunal’s forward-looking assessment sufficiently accounted for the deceased’s professional potential, and reducing compensation due to a technical overlap in methodology would not serve substantive justice, especially given the long passage of time since the accident.
In M. Paramesh v. VRL Logistics Ltd. (2026) INSC 655, the Supreme Court addressed an error in the calculation of future prospects by the High Court. The Court held that when an appellate court enhances the base monthly income of a claimant, the percentage allocated towards future prospects must be calculated on the revised or recalculated income, not mechanically applied to the lower income originally assessed by the Tribunal. The claimant in this case had suffered an above-the-knee amputation and would require lifelong medical assistance, rehabilitation, and periodic replacement or maintenance of the prosthesis. Consequently, the compensation under this head was enhanced from Rs. 1,00,000 to Rs. 2,00,000. The Court relied on Raj Kumar v. Ajay Kumar and Another ((2011) 1 SCC 343) in arriving at this conclusion.
Collectively, these judgments underscore the Supreme Court’s commitment to ensuring that victims of motor accidents receive fair and adequate compensation under the Motor Vehicles Act, 1988. The Court has consistently emphasized that the Act’s beneficial character demands a pragmatic and justice-oriented approach, particularly in assessing heads of compensation such as filial consortium, future prospects, and permanent disability, while also clarifying procedural principles governing the burden of proof and the apportionment of liability in road accident claims.