Pranav B Prem

The Supreme Court recently ruled that carpenters cannot be classified as unskilled workers, emphasizing the precision and expertise required for the craft. This landmark decision was delivered in the case Karamjit Singh v. Amandeep Singh & Anr. (Civil Appeal No. 27556 of 2023), where the Court enhanced the compensation awarded in a motor accident claim.

Case Background

The case revolves around Karamjit Singh, a carpenter by profession, who sustained life-altering injuries in a road accident on September 27, 2014. Singh was riding his motorcycle with his son, Dilpreet Singh, as a pillion rider, when they were hit by a vehicle owned by the first respondent (bearing registration number PB-12-R(T)7535) in Rupnagar, Punjab. As a result of the accident, Singh suffered severe injuries to his right arm and leg, along with multiple injuries on other parts of his body. He was immediately rushed to PGI Chandigarh for treatment and later referred to Sangh Hospital in Ropar. Despite extensive medical care, his injuries led to the amputation of his right arm on October 21, 2014. Singh subsequently filed an FIR (No. 178/2014) under Sections 279 (rash driving), 337 (causing hurt by an act of negligence), 338 (grievous hurt), and 427 (mischief causing damage) of the Indian Penal Code at Chamkaur Sahib Police Station, Rupnagar.

Initial Compensation Awards

Singh filed a compensation claim of ₹40,00,000, citing his loss of livelihood as a carpenter and the medical expenses incurred. The Motor Accidents Claims Tribunal (MACT) awarded him ₹6,83,982, which included amounts for pain and suffering, medical expenses, and loss of income. However, the Tribunal determined Singh’s monthly income at ₹5,000 due to the absence of documentary evidence. Aggrieved by the award, both Singh and the insurance company filed appeals. The Punjab and Haryana High Court revised the compensation to ₹8,26,000. This included ₹6,21,600 for loss of future earnings, ₹30,000 for loss of amenities, and ₹60,000 for pain and suffering. Singh, however, remained dissatisfied and approached the Supreme Court for further enhancement.

Supreme Court’s Observations

The Bench comprising Justice Sanjay Karol and Justice Manmohan highlighted the distinction between skilled and unskilled labor, stating: “A carpenter is somebody who uses wood and constructs objects for daily use or beauty, or even housing. A normal person who is not trained in the craft certainly cannot undertake these activities with the level of precision that is required. It would be unfair then, to classify a carpenter as an unskilled worker.” The Court also referred to the precedent set in State of Orissa v. Adwait Charan Mohanty (1995), which defined an artisan as “a person skilled in a trade, craft, or art requiring manual dexterity,” including carpentry. Additionally, in Neeta v. Maharashtra SRTC (2015), carpentry was acknowledged as a skilled job.

Compensation Enhancement

The Court applied the minimum wages notified for skilled workers by the Office of the Labour Commissioner, Punjab, at the relevant time. Taking into account a disability of 74% and future prospects as per National Insurance Company v. Pranay Sethi (2017), the Court computed the enhanced compensation as follows:

• Loss of Future Earnings: ₹10,36,467

• Future Prospects (25%): ₹3,50,158

• Pain and Suffering: ₹60,000

• Medical Expenses, Special Diet, Attendant, and Other Charges: ₹1,44,000

The final compensation amounted to ₹15,91,625, a significant increase from the High Court’s award of ₹8,26,000.

Verdict

Allowing the appeal, the Court stated: “The appeal is allowed in the aforesaid terms. The award of the Tribunal as modified by the High Court is further modified in terms of the Final Compensation column above.”

Cause Title: Karmajit Singh v. Amandeep Singh & Anr.

Case No: Special Leave to Appeal (C) No(s). 27556/2023

Date: December-17-2024

Bench: Justice Sanjay Karol, Justice Manmohan

[Read/Download order]