Pranav B Prem

The Supreme Court has ruled that a disability certificate issued by a duly constituted Medical Board should be accepted as expert evidence, and its findings cannot be reduced or disregarded without ordering a reassessment. The Court held that if a Tribunal doubts the medical certificate, it must direct a re-evaluation instead of arbitrarily substituting its own findings on disability.

Tribunal Cannot Override Medical Board’s Opinion Without Reassessment

A Bench comprising Justices Sanjay Karol and Manmohan set aside the Rajasthan High Court’s decision, which had reduced the compensation awarded to a motor accident victim who was certified as 100% disabled by a Medical Board. The High Court, affirming the Motor Accident Claims Tribunal’s (MACT) finding, had lowered the disability assessment to 50%, questioning the validity of the Medical Board’s certification due to the absence of specific testimony from a neurosurgeon.

The Supreme Court, however, emphasized: “The Tribunal questioned the competence of the Medical Board to assess the permanent disability of the claimant-appellant, terming the certificate of the Medical Board as not completely reliable. If the Tribunal had reason to doubt the medical certificate, the option available before it was to have the disability re-assessed but it could not have gone into the details of the determination of disability. Since that course of action has not been adopted, the opinion of the Medical Board, being an opinion of the experts is to be treated as such. That apart, the comatose state of the claimant-appellant is not in dispute.”

Facts of the Case

The case involved an appellant who suffered multiple injuries in a road accident and was left in a comatose state. He was granted compensation of Rs.16,29,465/- by the MACT, which was later increased to Rs.19,39,418/- by the High Court. However, the courts had reduced his disability percentage from 100% to 50% without ordering a reassessment. The appellant challenged this determination before the Supreme Court, arguing that both the MACT and the High Court had erred in unilaterally reducing the disability percentage when the Medical Board had certified him as 100% disabled. The Supreme Court found merit in this argument and reinstated the full disability assessment.

Compensation Reassessed by Supreme Court

The Supreme Court acknowledged the dire medical condition of the appellant and revised the compensation, awarding Rs.48,70,000/-. The Court observed: “The medical report clearly states that the claimant-appellant has no speech or intellectual functions. He cannot stand or walk and has a catheter. Further, he is dependent entirely on others for daily activities. The finding of 100% disability, therefore, appears to be justified.” The Court also noted the insufficiency of the amount awarded for pain, suffering, and attendant charges, stating that for a person in a coma who is entirely dependent on others, the previous awards were inadequate. It enhanced the compensation under various heads, including an additional Rs.7,80,000/- for attendant charges and Rs.6,00,000/- for pain and suffering.

Final Compensation Award

The Supreme Court determined the final compensation as follows:

The Court ordered the insurance company to pay the revised amount along with interest at 7% per annum from the date of filing the claim petition.

Cause Title: Prakash Chand Sharma V. Rambabu Saini & Anr. 

Citation: 2025 INSC 180  

Bench: Justice Sanjay Karol, Justice Manmohan

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