Appellate interference with MACT disability findings

The Supreme Court has reiterated that when an appellate court interferes with a Motor Accident Claims Tribunal’s findings on disability and loss of earning capacity, it must first undertake a thorough reappreciation of the evidence and record cogent reasons for departing from the Tribunal’s view.

The appeal arose from a road accident in which the claimant suffered grievous injuries, including a fracture of the left leg, facial injuries and a severe head injury. The MACT accepted the medical board’s disability certificate and assessed permanent disability at 63%. Applying the multiplier method, it awarded compensation of Rs.65,53,811 with interest.

The High Court reduced the disability assessment to 30% and brought down the compensation to Rs.35,61,000. It also reduced the amounts awarded under several heads, including loss of amenities and pain and suffering.

The Supreme Court found that the MACT had evaluated the oral and documentary evidence, including the claimant’s testimony, medical records, the disability certificate and salary documents, and had given a reasoned finding on the extent of disability and its effect on earning capacity. In contrast, the High Court’s interference did not meet the standard required when disturbing such factual findings.

The Court restored the MACT’s assessment of 63% disability and the compensation computed on that basis. It also reaffirmed that the Motor Vehicles Act, 1988 is a beneficial and welfare-oriented legislation intended to provide expeditious relief and just compensation to accident victims and their families.

The judgment was delivered by Justice Mehta, with Justice Vikram Nath and Justice Sandeep Mehta on the Bench.

Practical takeaway: appellate courts should not reduce MACT disability-based compensation without a full reappraisal of evidence and clear, convincing reasons.