Legal Review and Analysis of Riyas vs PN Shinosh & Anr 2025 INSC 1303
In-Short
Case: Riyas vs P.N. Shinosh & Anr. (2025 INSC 1303):
The Supreme Court enhanced compensation for a minor who suffered 77.1% permanent disability, emphasizing a liberal and holistic calculation that covers not just loss of future income but also significant amounts for pain and suffering, loss of marriage prospects, and other non-pecuniary damages to address the lifelong consequences of the injury.
1. Heading of the Judgment
Case Name: Riyas vs P.N. Shinosh & Anr.
Citation: 2025 INSC 1303
Court: Supreme Court of India
Jurisdiction: Civil Appellate Jurisdiction
Civil Appeal No.: 6544 of 2024
Judges: Justice N.V. Anjaria and Justice K. Vinod Chandran
Date of Judgment: November 10, 2025
2. Related Laws and Sections
The judgment pertains to the enhancement of compensation under the Motor Vehicles Act, 1988. The key legal provisions and precedents involved are:
Motor Vehicles Act, 1988:
Section 166: Application for compensation arising from a motor vehicle accident.Key Legal Precedents:
Master Mallikarjun vs. Divisional Manager, National Insurance Co. Ltd. (2014): Laid down principles for compensating children who suffer permanent disability.
National Insurance Company Limited vs. Pranay Sethi & Others (2017): Standardized the calculation of compensation, including the addition of future prospects to income and the application of a multiplier.
Sona (minor) vs. Manual C.M. (2025): A recent precedent with similar facts involving a minor with high permanent disability, used as a guiding case.
Kajal vs. Jagdish Chand (2020): Guided the assessment of compensation for loss of marriage prospects.
Sidram v. Divisional Manager, United India Insurance Ltd. (2023): Guided the award for special diet and transportation expenses.
K.S. Muralidhar v. R. Subbulakshmi & Anr. (2024): Guided the award for pain and suffering.
3. Basic Judgment Details
This civil appeal was filed by the claimant, Riyas, seeking further enhancement of the compensation awarded for injuries sustained in a motor vehicle accident. The appellant was a 14-year-old student at the time of the accident on April 19, 2002, and suffered 77.1% permanent disability. The Motor Accident Claims Tribunal, Thrissur, initially awarded Rs. 1,73,000/-. The Kerala High Court, in an appeal, enhanced the compensation by an additional Rs. 5,75,883/-. Dissatisfied, the appellant approached the Supreme Court for a further enhancement.
4. Core Principle and Analysis of the Judgment
The Main Issue: Whether the compensation awarded by the High Court to a minor who suffered 77.1% permanent disability in a motor accident was just, adequate, and in line with established legal principles, or if it required further enhancement.
Supreme Court's Reasoning and In-depth Analysis:
The Supreme Court's analysis focused on a comprehensive and liberal assessment of compensation to ensure it truly compensates for the profound and lifelong impact of the disability on a young victim. The core of the judgment is the application of established legal principles to the specific and grave facts of the case.
Application of Established Legal Principles to a Minor Victim: The Court began by affirming the High Court's correct application of the multiplier method as standardized in Pranay Sethi. It agreed with the use of a multiplier of 15 for a 14-year-old victim and the addition of 40% towards future prospects. The Court meticulously recalculated the core component for loss of future earnings due to disability. Using a notional monthly income of Rs. 3,620/-, adding 40% future prospects, applying the multiplier of 15, and then factoring in the 77.1% disability, the Court arrived at a figure of Rs. 7,03,337.04 under this head.
Liberal and Holistic Approach to Non-Pecuniary Damages: The Supreme Court significantly enhanced the compensation under various non-pecuniary heads, emphasizing that a high degree of permanent disability in a child warrants a more liberal interpretation. This was guided by the recent precedent in Sona (minor).
Pain and Suffering: Relying on K.S. Muralidhar, the Court enhanced this amount substantially to Rs. 3,00,000/- from the Rs. 30,000/- awarded by the High Court, recognizing the immense and enduring physical and mental agony.
Loss of Marriage Prospects: Guided by Kajal vs. Jagdish Chand, the Court recognized that a severe disability significantly impacts personal life. It enhanced this amount from Rs. 50,000/- to Rs. 3,00,000/-.
Attendant Charges and Other Expenses: The Court awarded Rs. 40,000/- for attendant charges, acknowledging the need for care during recovery. It also awarded Rs. 40,000/- for special diet and transportation, as per Sidram. For medical expenses, the Court adopted a pragmatic approach, awarding a lump sum of Rs. 50,000/- to cover both unproven out-of-pocket expenses during the 22-day hospitalization and potential future medical needs.
Loss of Amenities: The Court found the High Court's award of Rs. 80,000/- under this head to be just and did not alter it.
Conclusion of the Court on the Core Issue: The Supreme Court held that while the High Court correctly began the calculation using the multiplier method, the final compensation was inadequate. The Court emphasized that in cases of severe permanent disability to a minor, compensation must be computed liberally to account for the drastic alteration of the victim's entire life trajectory, encompassing not just economic potential but also personal, social, and marital prospects.
5. Final Outcome
The Supreme Court allowed the appeal and passed the following directions:
The total compensation payable to the appellant was enhanced to Rs. 15,13,337/- (rounded off).
Consequently, an additional compensation of Rs. 7,64,454/- was awarded over and above the amount granted by the High Court.
The Respondent No. 3-Insurance Company was directed to pay this additional amount with interest at the rate of 8% per annum from the date of the original application until its realization.
The insurance company was given 8 weeks to credit the amount to the appellant's bank account and produce proof of payment before the Tribunal.
6. MCQs Based on the Judgment
1. In the case of Riyas vs. P.N. Shinosh & Anr. (2025 INSC 1303), what was the key legal principle applied by the Supreme Court to calculate compensation for the minor's loss of future earnings?
a) The multiplier was determined based on the age of the vehicle's driver.
b) A notional income was taken, future prospects were added, a multiplier was applied, and the result was factored by the percentage of disability.
c) Compensation was based solely on the actual medical bills produced.
d) The multiplier was applied directly to the annual income without adding future prospects.
2. Which head of compensation saw the most significant enhancement by the Supreme Court in this judgment, reflecting the profound personal impact of the disability on the minor victim?
a) Special diet and transportation.
b) Attendant charges.
c) Loss of marriage prospects and Pain and suffering.
d) Loss of Amenities.
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