Legal Analysis: Prahlad Sahai vs. Haryana Roadways & Anr

Citation: 2026 INSC 396
Court: Supreme Court of India
Bench: Justice K.V. Viswanathan (Single Judge Bench)
Judgment Author: Justice K.V. Viswanathan
Date of Decision: April 21, 2026
Nature of Judgment: Civil Appeal under Article 136 against High Court judgment in motor accident claim.

Synopsis of the Judgment

The appellant, a 32-year-old driver, lost his right leg below the knee in a bus accident in 2007. The Tribunal awarded ₹8.73 lakhs compensation; the High Court enhanced it to ₹13.02 lakhs. The Supreme Court further enhanced the compensation to ₹36.20 lakhs (over and above the High Court’s award). The key issue was compensation for prosthetic limb(s). The Court held that a prosthetic limb is integral to the life of an amputee and that the principle of restitutio in integrum (restoration to original position) applies. The Court rejected government rates for prosthetics as “abysmally low,” holding that a claimant is entitled to choose a reasonable prosthetic from a private provider. Taking an assumed life expectancy of 70 years and a prosthetic life of 5 years, the Court awarded ₹3 lakhs per limb for 7 limbs (₹21 lakhs) plus ₹5 lakhs for maintenance. The Court also enhanced monthly income from ₹4,500 to ₹6,000, applied 40% future prospects, 100% functional disability, and multiplier of 16, awarding ₹16.12 lakhs for loss of future income. The appeal was allowed.

1. Basic Information of the Judgment

Field Details Case Title Prahlad Sahai vs. Haryana Roadways & Anr. Civil Appeal No. 4642 of 2026 (arising out of SLP(C) No. 8756/2024) Bench Justice K.V. Viswanathan Date of Decision April 21, 2026 Citation 2026 INSC 396 Appeal From Judgment of Punjab and Haryana High Court (date not specified)

2. Legal Framework

Laws and Provisions Involved:

• Motor Vehicles Act, 1988: Section 168 (determination of “just compensation”).

• Indian Evidence Act, 1872: Principles of proof of income for informal sector workers.

• Principle of Restitutio in Integrum: Restoration of the injured party to the original position as far as money can compensate.

• Principles of assessment: Compensation must be “just and reasonable” – not a pittance, not a windfall.

Precedents Cited:

• State of Haryana v. Jasbir Kaur (2003) 7 SCC 484 – Compensation for loss of limbs cannot be weighed in golden scales; must be just and reasonable.

• Hardeo Kaur v. Rajasthan State Transport Corpn. (1991) 2 SCC 603 – Ass

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