R. Halle v. Reliance General Insurance Company Limited 2026 INSC 260 - Motor Accident Compensation - Functional Disability

Motor Accident Compensation - The assessment of functional disability must be grounded in a realistic appraisal of the impact of the injury on the claimant’s capacity to earn. The inquiry is not confined to the numerical percentage of physical impairment certified by the Medical Board, but extends to evaluating whether the claimant, in light of his educational background, skill set and nature of employment, is capable of meaningfully pursue his avocation. (Para 28) [Context: Supreme Court held that the High Court had unjustifiably reduced the functional disability to 30% without properly re‑appreciating the uncontroverted medical and neuropsychological evidence, and assessed the appellant’s functional disability at 100% for loss of earning capacity. ]

Motor Accident Compensation - When an appellate court interferes with findings of fact duly recorded by the Motor Accidents Claims Tribunal, particularly on issues such as assessment of disability and loss of earning capacity, it is incumbent upon it to undertake a thorough reappreciation of the evidence and to assign cogent, clear and convincing reasons for departing from the conclusions arrived at by the Motor Accidents Claims Tribunal. Such an obligation is heightened in proceedings under the Motor Vehicles Act, 1988, which is a beneficial and welfareoriented legislation enacted with the object of ensuring expeditious relief and just compensation to victims of motor accidents and their families. The statutory framework is designed to advance social justice and to provide solace and financial security to those who suffer on account of road accidents. Any interference with a reasoned award of the Motor Accidents Claims Tribunal must, therefore, be consistent with the spirit and object of the enactment and supported by sound judicial reasoning.