LexR. HALLE versus RELIANCE GENERAL INSURANCE COMPANY LIMITED
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[2026] 4 S.C.R. 202 : 2026 INSC 260 R. Halle v. Reliance General Insurance Company Limited (Civil Appeal No. 3543 of 2026) 18 March 2026 [Prashant Kumar Mishra and Sandeep Mehta,* JJ.] Issue for Consideration The principal issue which falls for consideration is with regard to the assessment of extent of disability for the purpose of computing loss of earning capacity, and more particularly, the soundness of the High Court’s determination of functional disability at 30% as against 63% assessed by the Medical Board and affirmed by the MACT. Whether the appellant-claimant is entitled to any further enhancement of compensation over and above the amount awarded by the MACT. Headnotes† Motor Vehicle Accident claim – Enhancement of compensation – Motorcycle of appellant collided head-on with another motorcycle – Appellant sustained grievous injuries which led to 63% permanent disability – Claim petition filed – MACT quantified the total compensation at Rs.65,53,811 along with interest at the rate of 7.5% per annum from the date of petition till its realization to the appellant-claimant – Appeal before the High Court – The High Court, vide the impugned judgment dismissed the appeal filed by appellant-claimant seeking enhancement and partly allowed the appeal filed by the respondent-insurer thereby reducing the amount of compensation of Rs.65,53,811/- as awarded by MACT to Rs.35,61,000/- – Correctness: Held: In order to determine the functional disability suffered by the appellant-claimant, it is necessary to advert to the findings recorded by the Medical Board with respect to the permanent physical disability, as well as the neuropsychological assessment report placed on record – Both these documents remained uncontroverted and hence, they provide credible expert evidence so as to assess * Author [2026] 4 S.C.R. 203 R. Halle v. Reliance General Insurance Company Limited the extent and nature of disability – The injuries suffered by the appellant-claimant were not merely orthopedic in nature, but had significant neurological sequelae directly impacting his functional and cognitive abilities – When these physical and neurological impairments are cumulatively evaluated, it becomes manifest that the appellant-claimant’s ability to effectively discharge his pre- accident duties stands substantially and irreversibly impaired – The evidence does not indicate a mere diminution in efficiency, rather, it demonstrates a profound erosion of the faculties essential for gainful employment in his chosen field – In such circumstances, and bearing in mind the settled principle that functional disability must reflect the actual loss of earning capacity – The disability in the present case, for the purpose of computation of compensation, deserves to be reckoned at 100% – The appellant-claimant would neither be considered suitable for the managerial post nor would he be capable of effectively discharging the onerous responsibilities attached to the said post – The compensation payable to the appellant-claimant warrants re-determination – The total compensation payable to the appellant-claimant works out to Rs.97,73,011/- after calculating amounts under various heads – The impugned judgment passed by the High Court and the award passed by the MACT are modified in terms of this judgment. [Paras 25, 26, 30, 31, 34] Motor Vehicles Act, 1988 – Assessment of disability – Reappreciation of evidence by the Appellate Court – The Court to assign cogent, clear and convincing reasons: Held: 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 MACT – Such an obligation is heightened in proceedings under the Motor Vehicles Act, 1988, which is a beneficial and welfare oriented 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 204 [2026] 4 S.C.R. Supreme Court Reports award of the Motor Accidents Cl
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