The Andhra Pradesh High Court considered an appeal arising from a motor vehicle accident claim involving permanent partial disability. In the underlying case, the claimant had suffered approximately forty percent permanent and partial disability, which led to difficulty in chewing and altered speech. The accident, caused by rash and negligent driving of an APSRTC bus, resulted in serious physical impairment. The Motor Accidents Claims Tribunal awarded compensation of ₹6,89,000 with interest at seven‑and‑a‑half percent per annum. Notably, the Tribunal did not award any compensation under the head of permanent disability, reasoning that the claimant’s employment and income remained unaffected despite the persistent impairment.
Challenging this outcome, the claimant filed an appeal asserting that denial of permanent disability compensation was unjustified, notwithstanding the preservation of income. The drivers of the offending vehicle and APSRTC officials cross‑appealed, arguing that the claimant’s own contributory negligence had been ignored, and that compensation should be reduced. They further contended that since the claimant continued to receive employment and medical reimbursement, there was no justification for awarding permanent disability head.
A Single Judge, Justice A. Hari Haranandha Sarma, engaged with these submissions and carefully analysed the law relating to functional disability, income continuity, and loss. The Court observed that functional disability and loss of income are distinct: while a disability may not impact earnings directly, it can cause daily inconvenience, requiring ongoing expenditure on transportation, attendant care, special diet, or adaptation. Functional disability refers to limitations in performing day‑to‑day activities, separate from the capacity to earn wages. A person may remain employed with unchanged pay, yet suffer substantial impairment in routine life and incur additional costs beyond office hours, which should be compensated.
The judgment clarified that continued employment with unchanged income does not preclude entitlement to compensation under ‘permanent disability’. Even where income is unaffected, the disability may force an individual to bear extra expenses related to daily living, treatment, physical pain, and emotional trauma. The Court recognised that applying scientific precision to quantify such loss may be difficult, but emphasized the practical reality of enduring hardships and additional financial burdens that accompany permanent impairment.
Focusing on the case at hand, the Court noted that the forty‑percent disability substantially impairing chewing and speech represents a significant functional limitation. It concluded that additional expenses incurred as result of the impairment cannot be overlooked merely because income streams persist unchanged. The learned Judge observed that denial of permanent disability compensation on narrow understanding—i.e. income continuity alone—would undermine the compensatory jurisprudence designed to restore the injured person’s life as far as possible to normalcy.
The reasoning affirmed that functional disability may lead to realistic loss—beyond economic loss—which justifies compensation under the head of permanent disability even in absence of demonstrable wage loss. Further, the Court emphasised that the Tribunal’s approach failed to appreciate the broader mandates of the Motor Vehicles Act and compensatory principles which aim for equitable relief in circumstances where long‑term impairment persists. Even if salary remains the same, the injury’s impact—both personal and financial—must be recognised.
Consequently, the Andhra Pradesh High Court allowed the claimant’s appeal to the extent relevant to permanent disability. It held that denial of compensation under that head was erroneous and remanded the matter for reassessment in accordance with its clarified principles. The cross‑appeals by the driver and APSRTC officials were partially addressed: the Court found insufficient basis to reduce compensation for contributory negligence or use of medical reimbursement as ground to deny disability relief. The ruling reinforced that employment security or reimbursement benefits do not negate compensatory rights where impairment causes ongoing discomfort and financial strain.
The judgment underlines that the claim for permanent disability is separate from and not contingent upon demonstrable loss of earnings, and holds that additional life costs arising from permanent impairment must be acknowledged by statutory compensation. By affirming entitlement to disability compensation despite continuity of income, the Andhra Pradesh High Court reaffirmed a broader, person‑centred approach in motor accident compensation jurisprudence, insisting that disability awards consider the enduring effects of injury on daily life, personal dignity, and unrecouped expenses.
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