New Delhi, March 18 Appellate courts must carefully re-examine the evidence and provide clear reasons before altering the findings and compensation awarded by the Motor Accident Claim Tribunals in accident cases governed by welfare legislation, the Motor Vehicles Act, the Supreme Court said on Wednesday.
The observations were made by the top court in a judgment in which it enhanced the compensation awarded to a former manager from Rs 35.61 lakh to Rs 97.73 lakh in a road accident case.
“Before concluding the matter, we deem it appropriate to reiterate that when an appellate court interferes with the findings of fact duly recorded by the Motor Accidents Claims Tribunal (MACT), particularly on issues such as assessment of disability and loss of earning capacity, it is incumbent upon it to undertake a thorough re-examination of the evidence and to assign cogent, clear, and convincing reasons for departing from the conclusions arrived at by the MACT,” a bench comprising Justices Prashant Kumar Mishra and Sandeep Mehta said.
Justice Mehta, who authored the judgment, said that such an obligation is more on appellate courts in proceedings under the Motor Vehicles Act, 1988, “which is a beneficial and welfare-oriented legislation enacted with the object of ensuring expeditious relief and just compensation to victims of motor accidents and their families.”
The bench said that 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 verdict said.
The top court set aside a 2022 order by the Madras High Court which had drastically reduced the victim's compensation and held that severe cognitive impairment and brain injuries should be treated as 100 per cent "functional disability" when they prevent a victim from performing their professional duties.
In the instant case, appellant R Halle was working as a manager at a logistics firm in Chennai when he met with a head-on motorcycle collision on May 5, 2016.
The accident resulted in a severe head injury, facial fractures, and a broken femur. While the MACT initially awarded him Rs 65.53 lakh based on a 63 per cent physical disability, the Madras High Court later slashed this to Rs 35.61 lakh, reducing his functional disability to just 30 per cent.
The top court rejected the high court’s approach and noted that it had "abruptly concluded" the disability was lower without analyzing the medical evidence.