Legal Review and Analysis of Sharad Singh Dead Through Legal Representative vs H D Narang & Anr 2025 INSC 1164

1. Heading of the Judgment

Case Title: Sharad Singh (Dead) Through Legal Representative vs. H.D. Narang & Anr.
Citation: 2025 INSC 1164
Court: Supreme Court of India
Civil Appeal No.: 8136 of 2024
Judges: Justice K. Vinod Chandran and Justice N.V. Anjaria
Date of Judgment: September 26, 2025

2. Related Laws and Legal Principles

The judgment primarily engages with the law of torts and motor accident claims. The key legal principles and precedents invoked are:

• Motor Vehicles Act, 1988: The foundational law for claiming compensation for injuries/death arising from motor vehicle accidents.

• Pranay Sethi & Others vs. National Insurance Company Limited, (2017) 16 SCC 680: This Constitution Bench judgment is a landmark precedent that laid down a standardized formula for calculating compensation, including the application of a multiplier based on the age of the victim and the addition of a certain percentage for "future prospects" of income growth.

• Principles of "Just Compensation": The overarching principle that compensation must be equitable, realistic, and sufficient to restore the victim, to the extent possible, to the position they would have been in had the accident not occurred. This includes compensation for actual expenses, loss of income, pain and suffering, and future medical needs.

3. Basic Judgment Details

This is an appeal against the order of the High Court, which itself was an appeal against the order of the Motor Accidents Claims Tribunal (MACT). The appellant is the mother of the victim, Sharad Singh, who, at the age of 20, suffered a severe spinal injury (C4-5 fracture) in a 2001 accident caused by the negligent driving of Respondent No. 1. The injury resulted in 100% disability (paraplegia), rendering him bedridden until his death in 2021. The appeal was focused solely on challenging the quantum of compensation awarded by the lower courts, specifically regarding the calculation of loss of income and the reimbursement of future medical expenses.

4. Core Principle and In-Depth Analysis of the Judgment

The core of this judgment revolves around the Supreme Court's intervention to ensure that the compensation awarded is not merely formulaic but is "just" and reflective of the victim's true potential and actual suffering. The Court adopted a liberal and pragmatic approach, moving beyond rigid adherence to minimum wages to consider the victim's proven academic trajectory and the harsh realities of his post-accident life.

A. The Primary Issues Addressed

The Supreme Court addressed two central issues in its analysis:

1. The correct determination of the victim's income and future prospects for calculating "loss of income."

2. The reimbursement of substantial medical expenses incurred by the victim's parents after the High Court's decision and until his death.

B. Analysis of the Issue of Loss of Income and Future Prospects

The Tribunal and the High Court had computed the loss of income based on the minimum wages applicable to a "skilled worker" in Delhi in 2001 (approximately Rs. 3,350 per month). The appellant argued that this was unjust for a final-year B.Com student who had enrolled for the Chartered Accountancy course.

• Supreme Court's Reasoning: The Court agreed with the appellant. It held that adopting minimum wages for a graduate on the verge of a professional career was unrealistic. The Court recognized that even if the victim had not become a Chartered Accountant immediately, his graduation would have secured him a job as an Accountant. Based on a "reasonable estimate," the Court determined that a monthly income of Rs. 5,000/- in 2001 was a more accurate starting point.

• Application of Precedent: Following the precedent set in Pranay Sethi, the Court added 40% to this income as "future prospects" to account for his potential career growth. The multiplier of 18 (correctly applied by the High Court based on the victim's age of 20) was used. Thus, the loss of income was recalculated as:
  Rs. 5,000 (Monthly Income) + 40% (Future Prospects) = Rs. 7,000 per month.
  Rs. 7,000 x 12 months x 18 multiplier = Rs. 15,12,000.

C. Analysis of the Issue of Medical Expenses

A significant amount of medical expenses (bills totaling Rs. 38 lakhs) was incurred after the High Court's order and until the victim's death. The Insurance Company initially contested these bills, arguing they were from hospitals in Goa and Bengaluru instead of Delhi, and were difficult to verify.

• Supreme Court's Reasoning: The Court dismissed the Insurance Company's objection, noting that a national company has the resources to verify bills from any part of India. It accepted the appellant's explanation that the victim was moved to Goa due to Delhi's adverse climate, which aggravated his pneumonia, a common complication for paraplegics.

• Verification and Award: The Court directed the appellant to tabulate the bills and the Insurance Company to verify them. The Company verified and admitted that bills worth Rs. 21 lakhs were genuine. Since the High Court had already granted an additional Rs. 1 lakh for medical expenses, the Supreme Court deducted this amount and awarded the remaining Rs. 20 lakhs as reimbursement for the future medical expenses incurred by the parents.

5. Final Outcome and Supreme Court's Directions

The Supreme Court allowed the appeal and modified the compensation as follows:

1. Loss of Income: Enhanced to Rs. 15,12,000 from the High Court's award of Rs. 7,24,032.

2. Conventional Heads (Attendant charges, pain and suffering, etc.): Rs. 14,00,000 (as awarded by the High Court, and not interfered with).

3. Medical Expenses (as per Tribunal/High Court): Rs. 11,22,356 (as awarded by the High Court).

4. Total Compensation (1+2+3): Rs. 40,34,356.

5. Future Medical Expenses (Additional Award): Rs. 20,00,000.

Directions:

• The total compensation of Rs. 40,34,356 will carry interest at 9% per annum from the date of the original petition until its realization.

• The additional Rs. 20,00,000 for future medical expenses must be paid within four months. If paid within this period, it will not carry interest. If delayed, it will attract 9% interest from the date of this judgment.

• The entire awarded amount is to be paid to the appellant (the victim's mother) within four months.

6. MCQs Based on the Judgment

Question 1: In the case of Sharad Singh vs. H.D. Narang & Anr. (2025 INSC 1164), on what primary ground did the Supreme Court enhance the calculation of the victim's loss of income?

a) By applying a higher multiplier of 20 instead of 18.
b) By rejecting the minimum wage calculation and adopting a higher estimated income based on the victim's educational potential.
c) By awarding a full Chartered Accountant's salary as the victim was enrolled in the course.
d) By adding 50% for future prospects instead of the standard 40%.

Answer: b) By rejecting the minimum wage calculation and adopting a higher estimated income based on the victim's educational potential.

Question 2: Regarding the medical expenses incurred in Goa, what was the Supreme Court's view on the Insurance Company's argument that the bills were difficult to verify?

a) The Court agreed and disallowed those expenses.
b) The Court held that a national insurance company cannot plead inability to verify bills from any part of India.
c) The Court reduced the amount by 50% due to lack of proper documentation from Delhi hospitals.
d) The Court directed the appellant to get the bills re-verified by a local court in Goa.

Answer: b) The Court held that a national insurance company cannot plead inability to verify bills from any part of India.