Appellate Court Should Not Lightly Interfere With MACT Compensation : Supreme Court

The Supreme Court on Wednesday (March 18) held that appellate courts cannot interfere with the assessment of disability and compensation determined by the Motor Accident Claims Tribunal unless they undertake a thorough reappreciation of evidence and provide clear and convincing reasons. “…when an appellate court interferes with findings of fact duly recorded by the Motor Accidents Claims Tribunal, particularly on issues such as assessment of disability and loss of earning capacity, it is incumbent upon it to undertake a thorough reappreciation of the evidence and to assign cogent, clear and convincing reasons for departing from the conclusions arrived at by the Motor Accidents Claims Tribunal.”, observed a bench of Justices Prashant Kumar Mishra and Sandeep Mehta. The case arose from a motor accident claim in which the claimant had suffered severe injuries, including head trauma and cognitive impairment, resulting in 63% permanent disability. The MACT, after evaluating medical evidence, awarded compensation of ₹65.53 lakh. However, the High Court reduced the functional disability to 30% and consequently lowered the compensation, without a detailed analysis of the evidence. Aggrieved, the claimant appealed to the Supreme Court. Setting aside the impugned findings, the judgment authored by Justice Mehta mere substitution of views by the Appellate Court without proper analysis is impermissible. The Court reasoned that since the Motor Vehicle Act is a beneficial provision enacted with the object of ensuring expeditious relief and just compensation to victims of motor accidents and their families, any interference with the award of compensation must be consistent with the spirit and object of the enactment and supported by sound judicial reasoning. “The statutory framework is designed to advance social justice and to provide solace and financial security to those who suffer on account of road accidents. Any interference with a reasoned award of the Motor Accidents Claims Tribunal must, therefore, be consistent with the spirit and object of the enactment and supported by sound judicial reasoning.”, the court observed.Reiterating settled principles from Raj Kumar v. Ajay Kumar, the Court emphasised that while physical disability cannot always be equated with loss of earning capacity, any departure from medical evidence must be supported by cogent reasoning.The Court increased the compensation from ₹35.61 lakh (as fixed by the Madras High Court) to ₹97.73 lakh, restoring and expanding the approach adopted by the Motor Accidents Claims Tribunal (MACT).The appeal was allowed.HeadnoteMotor Vehicles Act, 1988 – Assessment of Disability and Loss of Earning Capacity – Functional Disability vs. Physical Disability – The Supreme Court set aside the High Court's decision to reduce the functional disability of the appellant-claimant from 63% to 30% - held that the High Court failed to provide cogent reasons for disregarding the Medical Board's certificate and the neuropsychological report which evidenced severe cognitive impairment, partial blindness, and intellectual disability resulting from a head injury - Noted that for a professional like a Manager, whose role depends on memory and analytical skills, such neurological deficits lead to a profound erosion of faculties essential for employment - the Supreme Court enhanced the functional disability to 100% for the purpose of computing compensation - Supreme Court increased the compensation from ₹35.61 lakh (as fixed by the Madras High Court) to ₹97.73 lakh, restoring and expanding the approach adopted by the Motor Accidents Claims Tribunal (MACT). [Paras 21 - 30]Motor Vehicles Act, 1988 – Duties of Appellate Courts – When an appellate court interferes with the findings of fact recorded by the Motor Accidents Claims Tribunal (MACT), especially regarding disability assessment, it must undertake a thorough reappreciation of evidence and assign clear, convincing reasons - Mechanical reductions of compensation without independent analysis of medical records are not sustainable in law – Appeal allowed. [Relied on Raj Kumar v. Ajay Kumar (2011) 1 SCC 343; Paras 22 - 35]Cause Title: R. HALLE VERSUS RELIANCE GENERAL INSURANCE COMPANY LIMITEDCitation : 2026 LiveLaw (SC) 261Click here to download judgmentAppearance: For Petitioner(s) : Ms. Haripriya Padmanaban, Sr. Adv. Mr. S. Prabu Ramasubramanian, Adv. Mr. Raghunatha Sethupathy B, AOR Mr. Manoj Kumar A., Adv. Ms. Trisha Chandran, Adv. For Respondent(s) : Ms. Prerna Mehta, AOR

Appellate Court Should Not Lightly Interfere With MACT Compensation : Supreme Court

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Yash Mittal

Appellate Court Should Not Lightly Interfere With MACT Compensation : Supreme Court

Yash Mittal

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Yash Mittal

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