Prahlad Sahai v. Haryana Roadways 2026 INSC 396 - Motor Accident Compensation - Prosthetic Limb
Seventy years as the standard life expectancy, a five‑year life for each prosthetic limb
Motor Accident Compensation - The Supreme Court considered how to compute “just compensation” for an amputee under the specific head of prosthetic limb (purchase and lifelong replacement/maintenance), in a motor accident case where the claimant’s right leg was amputated below the knee. Treating seventy years as the standard life expectancy, a five‑year life for each prosthetic limb, and 100% functional disability of a driver earning Rs. 6,000 per month, the Court awarded compensation for seven limbs at Rs. 3,00,000 each plus Rs. 5,00,000 towards lifelong maintenance, and enhanced loss of future income and other heads. The appeal was allowed, directing the insurer to pay a further Rs. 36,20,350 over and above the High Court’s award, while reiterating that future prosthetic‑limb claims must be supported by quotations and that governmental price notifications cannot limit reasonable, restitutive compensation.
Case Info
Case Information Extracted
Case name and neutral citation:Prahlad Sahai v. Haryana Roadways & Anr., 2026 INSC 396
Coram:Justice J.B. Pardiwala and Justice K.V. Viswanathan (judgment authored by K.V. Viswanathan, J.)
Judgment date:21 April 2026 (New Delhi)
Case laws and citations referred
- State of Haryana and Another v. Jasbir Kaur and Others, (2003) 7 SCC 484
- National Insurance Company Limited v. Pranay Sethi and Others, (2017) 16 SCC 680
- Smt. Sarla Verma & Others v. Delhi Transport Corporation & Another, (2009) 6 SCC 121
- Chandra and Another v. Mukesh Kumar Yadav and Others, (2022) 1 SCC 198
- Ramachandrappa v. Manager, Royal Sundaram Alliance Insurance Company Limited, (2011) 13 SCC 236
- Syed Sadiq and Others v. Divisional Manager, United India Insurance Company Limited, (2014) 2 SCC 735
- Hardeo Kaur v. Rajasthan State Transport Corpn., (1992) 2 SCC 567
- Mohd. Sabeer @ Shabir Hussain v. Regional Manager, U.P. State Road Transport Corporation, 2022 SCC OnLine SC 1701
- Chandra Mogera v. Santosh A. Ganachari & Anr., Civil Appeal No. 12183 of 2025, decided on 11.09.2025
- Jai Bhagwan v. Laxman Singh, (1994) 5 SCC 5
- Helen C. Rebello v. Maharashtra SRTC, (1999) 1 SCC 90
Foreign decisions cited:12. David Pinnington v. Crossley [2003] EWCA Civ 168413. A (suing by her litigation friend Mrs H) v. Powys Local Health Board [2007] EWHC 2996 (QB)14. Kerry Donnelly v. Fas Products Ltd, 2004 S.C.L.R. 678 (UK)15. H. West & Son Ltd. v. Shephard, (1963) 2 All ER 62516. Admiralty Comrs. v. The Susquehanna, (1926) All ER 124; 1926 AC 655Plus English authorities referred via quotations: Rialis v. Mitchell; Sowden v. Lodge; Massey v. Tameside and Glossop Acute Services NHS Trust [2007] EWHC 317 (QB); Taylor v. Chesworth and MIB [2007] EWHC 1001 (QB).
Statutes / laws referred
- Motor Vehicles Act, 1988 – Section 168 (just compensation)
- Government of India Notification dated 09.07.2024 on prosthetic pricing (rejected as benchmark)
- (Comparative reference) Law Reform (Personal Injuries) Act 1948, Section 2(4) (UK)
- General principles of restitutio in integrum (as explained via case law and Ramanatha Aiyar’s Advanced Law Lexicon)
Brief three-sentence summaryThe Supreme Court considered how to compute “just compensation” for an amputee under the specific head of prosthetic limb (purchase and lifelong replacement/maintenance), in a motor accident case where the claimant’s right leg was amputated below the knee. Treating seventy years as the standard life expectancy, a five‑year life for each prosthetic limb, and 100% functional disability of a driver earning Rs. 6,000 per month, the Court awarded compensation for seven limbs at Rs. 3,00,000 each plus Rs. 5,00,000 towards lifelong maintenance, and enhanced loss of future income and other heads. The appeal was allowed, directing the insurer to pay a further Rs. 36,20,350 over and above the High Court’s award, while reiterating that future prosthetic‑limb claims must be supported by quotations and that governmental price notifications cannot limit reasonable, restitutive compensation.
