Prosthetic Limb Costs Must Also Be Compensated To Restore Accident Victims To Dignified Life: Supreme Court

The Supreme Court has held that compensation awarded to motor accident victims must include the cost of prosthetic limbs and their maintenance, emphasizing that such devices are essential to restoring mobility, confidence, and dignity to amputees.

Observing that a prosthetic limb is integral to the life of a person who has lost a limb, the Court underscored that compensation must aim to place the injured person, as far as possible, in the position they would have occupied prior to the accident.

A bench of Justice JB Pardiwala and Justice KV Viswanathan, hearing an appeal arising out of a bus accident of 2007, noted that neither the Motor Accident Claims Tribunal nor the High Court had awarded any amount towards prosthetic limb expenses, despite the claimant having suffered amputation of his right leg.

The Court emphasized that the mandate under Section 168 of the Motor Vehicles Act is to award “just compensation,” which must be fair, reasonable, and responsive to the actual needs of the injured person.

Highlighting the principle of restitutio in integrum, the Court stated that damages should enable the victim to procure necessary aids and equipment required due to the injury.

Prosthetic Limb Not A One-Time Expense

The Court recognized that prosthetic limbs are not permanent devices and typically require replacement at periodic intervals. It accepted that an artificial limb generally needs replacement once every five years and that maintenance costs must also be factored into compensation.

Applying an assumed life expectancy of 70 years and a five-year replacement cycle, the Court calculated that the claimant, who was 32 years old at the time of the accident, would require seven prosthetic limbs during his lifetime.

Accordingly, the Court awarded ₹3,00,000 per prosthetic limb and ₹5,00,000 towards maintenance expenses, resulting in a total of ₹26 lakh under the head of prosthetic limb costs.

Government Rates Not Binding If They Do Not Meet Reasonable Needs

The Court rejected the insurer's reliance on government-notified rates that suggested much lower prices for prosthetic devices, holding that compensation must reflect the claimant's reasonable requirements rather than the cheapest available option.

It clarified that a claimant is entitled to procure a prosthetic limb from an appropriate private provider if that choice is reasonable in light of their medical and functional needs.

The Court followed the 2022 judgment in Mohd. Sabeer @ Shabir Hussain v. Regional Manager, U.P. State Road Transport Corporation in which the cost of prosthetic limb was taken as Rs 3 lakh.

Background

The case arose from a 2007 accident in which a Haryana Roadways bus hit the claimant's motorcycle, resulting in amputation of his right leg below the knee. The Motor Accident Claims Tribunal had initially awarded ₹8.73 lakh, which was later enhanced to ₹13.02 lakh by the Rajasthan High Court.

Allowing the appeal, the Supreme Court enhanced compensation under multiple heads, including loss of future income and litigation expenses, and awarded a consolidated amount of ₹26 lakh towards prosthetic limb cost and maintenance.

The Court directed the insurer to pay a total additional amount of ₹36.2 lakh, over and above the compensation awarded by the High Court, within four weeks.

Headnote

Maintenance – Computation and Jurisprudential Basis – Principles of Restitutio in Integrum - The Supreme Court examined the jurisprudential framework for computing and awarding compensation under the head of "Prosthetic Limb" in motor accident cases - Emphasizing the mandate of Section 168 to determine "just compensation", Supreme Court reiterated that while damages cannot be arrived at by precise mathematical calculations or expected to be a windfall, they must represent equitability, fairness, and reasonableness, avoiding a pittance - Key Principles Established by the Court- i. Standard Formula for Prosthetic Replacement - Following its prior ruling in Chandra Mogera v. Santosh A. Ganachari & Anr. (2025) and Mohd. Sabeer @ Shabir Hussain v. Regional Manager, U.P. State Road Transport Corporation (2022), the Court recognized a block of five (5) years as the reasonable replacement period for a prosthetic limb, with an assumed maximum life expectancy of 70 years for the claimant; ii. Governmental Rates Not Binding - The Court categorically rejected the abysmally low pricing slabs prescribed under Government Notifications - Grounded in the principle of restitutio in integrum (restoring the injured party to their original position as far as money can buy) , held that if the treatment or device chosen by the claimant is reasonable to meet their needs, the insurer/respondent cannot compel them to accept cheaper options or government-subsidized alternatives; iii. Requirement of Price Quotations - Supreme Court reiterated the mandatory directive from Chandra Mogera (supra)that any future claim for compensation under the head of a prosthetic/artificial limb must be accompanied by genuine price quotations from at least two or three service providers to enable tribunals to make an informed, actual cost assessment; iv. Assessment of Income Without Documentary Evidence - Relying on Ramachandrappa (2011) and Syed Sadiq (2014), the Court held that a claim for monthly income cannot be rejected merely due to a lack of documentary evidence if the claimed amount is reasonable considering the specific strata of income, year of the accident, and nature of employment (e.g., heavy vehicle driver). [Relied on Syed Sadiq v. Divisional Manager, United India Insurance Co. Ltd. (2014) 2 SCC 735; Chandra Mogera v. Santosh A. Ganachari & Anr. (Civil Appeal No. 12183/2025); Paras 25-35]

Case : Prahlad Sahai v Haryana Roadways and anr

Citation : 2026 LiveLaw (SC) 407

Click here to read the judgment

Appearances :

Adv Anuj Bhandari for the appellant; Adv Akshay Amritanshu Haryana Roadways Corporation; Sr Adv Vishnu Mehra for the Insurance Company