Summary and Analysis of Lokesh B vs Suryanarayana Raju & Anr. (Civil Appeal Nos. _____ of 2025)

1. Heading of the Judgment

Lokesh B vs Suryanarayana Raju & Another
(Supreme Court of India, Civil Appellate Jurisdiction)
Citation: (2025) INSC 939

2. Related Laws and Precedents

The judgment relies on:

• Motor Vehicles Act, 1988: Compensation principles for accident victims.

• Precedents:
  Santosh Devi v. National Insurance Co. Ltd. (2012): Recognized future prospects for self-employed victims.
  Pranay Sethi v. National Insurance Co. Ltd. (2017): Affirmed 40% future prospects for self-employed persons aged 40 or below.

3. Basic Case Details

• Parties:
  Appellant: Lokesh B (38-year-old tailor injured in a road accident).
  Respondents: Lorry owner (Suryanarayana Raju) and insurer (Shriram General Insurance Co. Ltd.).

• Accident (19 November 2016):
  Lokesh’s car collided with a stationary lorry parked without indicators on Peenya Flyover, Bengaluru.
  Injuries: Skull fractures, brain hemorrhage, optic nerve damage (causing visual impairment), and bilateral wrist fractures.

• Lower Courts’ Decisions:
  Tribunal (2018): Awarded ₹13.60 lakhs after deducting 20% for contributory negligence.
  High Court (2021): Reduced compensation to ₹13.44 lakhs by excluding future prospects and underestimating disability.

4. Explanation of the Judgment

Core Issues

1. Whether the High Court erred in excluding future prospects for a self-employed victim.

2. Whether the disability assessment (35%) was arbitrary against medical evidence.

Supreme Court’s Ruling

1. Future Prospects Rightfully Included:
   The High Court wrongly denied future prospects despite precedents (Santosh Devi, Pranay Sethi) mandating it for self-employed victims.
   Calculation:
   Monthly income: ₹9,500 (accepted by both parties).
   40% future prospects added: ₹9,500 + ₹3,800 = ₹13,300/month.

2. Disability Percentage Revised to 41.77%:
   Medical evidence from NIMHANS (PW-3) proved 41.77% neuro-cognitive disability using standardized tests.
   The Tribunal and High Court arbitrarily adopted 35% without justification.
   Court’s View: Functional disability must align with unimpeached medical evidence.

Revised Compensation Breakdown

• Loss of Future Earnings:
  Annual income: ₹13,300 × 12 = ₹1,59,600.
  With 41.77% disability and multiplier of 15 (age 38): ₹1,59,600 × 15 × 41.77% = ₹9,99,974.

• Other Heads (Unchanged from High Court):
  Medical expenses: ₹8,18,140.
  Pain and suffering: ₹75,000.
  Attendant/conveyance: ₹20,000.
  Loss of income during treatment: ₹38,000.
  Loss of amenities: ₹1,25,000.

• Total: ₹20,76,114.

• Less 20% contributory negligence: ₹16,60,891 payable.

Final Order

• Compensation enhanced from ₹13.44 lakhs to ₹16.60 lakhs.

• Insurer directed to deposit balance within 6 weeks.

• Interest: 6% per annum from claim petition date.

Key Legal Principles Reaffirmed

1. Self-Employed Victims Entitled to Future Prospects:
   Economic potential must be factored into compensation (Pranay Sethi).

2. Medical Evidence Prevails:
   Courts cannot arbitrarily override uncontroverted disability assessments.

3. Contributory Negligence:
   Deduction upheld (20%) as appellant did not challenge this finding.

Significance:
The judgment ensures accident victims receive just compensation by strictly applying precedents and medical evidence, preventing arbitrary reductions.