PARMINDER SINGHversusHONEY GOYAL AND OTHERS

                   [2025] 4 S.C.R. 50 : 2025 INSC 361

                            Parminder Singh
                                  v.
                         Honey Goyal and Others
                        (Civil Appeal No. 4299 of 2025)
                                 18 March 2025
             [J.K. Maheshwari and Rajesh Bindal,* JJ.]


                            Issue for Consideration
       Matter pertains to the enhancement of the amount of compensation
       granted to the appellant, aged 21 years, a veterinary student and
       State Level player in Volleyball who sufferred quadriplegia-paralysis
       of all four limbs after being hit by the car and was declared 100%
       disabled.

                                    Headnotes†
       Motor Vehicles Act, 1988 – Motor accident – Compensation –
       Enhancement – Appellant, aged 21 years, veterinary student
       and a State Level player in Volleyball hit by a car resulting in
       quadriplegia-paralysis of all four limbs, and declared 100%
       disabled – Claim petition – Tribunal awarded ₹5,16,000/-
       as compensation – In appeal, the High Court enhanced
       compensation to ₹15,25,600/- – Challenge to:
       Held: Income of the appellant has been taken on the lower side,
       which deserves to be enhanced – Appellant was a good sportsman
       and had certain technical qualification to his credit, taking his income
       merely at ₹5,600/- per month was not appropriate, it was less than the
       minimum wage for unskilled worker – Thus, his income is assessed
       as ₹7,500/- per month – High Court rightly applied the multiplier
       of 18 but failed to grant future prospects under the head ‘Loss of
       Income’ which should be 40% and income after taking into account
       future prospects would be ₹10,500/- per month (₹7,500x1.4) –
       Also, judicial notice taken of the fact that physiotherapy would
       be required – In view thereof, total compensation amounting
       to Rs. 36,84,000/- awarded, assessed under the heads-loss of
       income, medical expenses, attendent charges, special diet, pain
       and sufferring, expenses towards physiotherapy, future medical
       expenses, and loss of marriage prospects – Impugned order

* Author
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              Parminder Singh v. Honey Goyal and Others


     modified to that extent – Enhanced amount of compensation be
     calculated and transferred in the bank account of the appellant by
     the Insurance Company within the stipulated period. [Paras 9-13]

     Directions by Supreme Court – Motor accident cases – Mode
     of payment of compensation:
     Held: No uniform practice followed regarding deposit of the amount
     before the tribunal, whether the amount would remain in government
     treasury or would be transferred in bank to be kept in interest bearing
     fixed deposits – General practice followed by the insurance companies
     is to deposit the same before the tribunal – Instead of following that
     process, mode of payment of compensation to be streamlined by
     directly transferring the amount in the bank accounts of the claimants
     with intimation to the tribunal, to save the insurance companies and
     the claimants from the hassles of the court processes– Tribunal
     may require claimants to furnish their bank particulars at the initial
     stage of the pleadings – If there is no bank account, then claimants
     should be required to open it – Change in bank account particulars
     to be updated before the tribunal – Bank account to be in the name
     of the claimant and if minor, through guardian who is a family
     member – Where tribunal directs for keeping a certain percentage
     of the amount in the fixed deposit, such direction can always be
     issued in the award itself to be complied with by the bank – Real
     object of beneficial legislation, to compensate for the loss of earning
     member of the family or for the injuries suffered by the claimant, would
     be achieved, and compensation can be disbursed without delay if
     process of direct transfer to bank is followed – Directions being issued
     for bank transfer of the amount of compensation in motor accident
     cases, can always be followed by courts/tribunals in any matter.
     [Paras 14, 14.6, 17-20]

                               Case Law Cited
     Haryana State Industrial Development Corporation v. Pran Sukh
     and Others (2010) 11 SCC 175; Haryana State Industrial &
     Infrastructure Development Corporation Ltd. v. Smt. Krishna Rani
     & Another, R.F.A. No.1492 of 2008 – referred to.

                                  List of Acts
     Motor Vehicles Act, 1988; Code of Criminal Procedure, 1973;
     Domestic Violence Act, 2005.
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                                       List of Keywords
       Motor accident case; Compensation; Compensation in motor accident
       case; Loss of income; Loss of marriage prospects; Compensation
       for pain and suffering; Expenses for physiotherapy; Expenses for
       attendant; Quadriplegia; Compensation for special diet; Bank transfer
       of compensation; Unified Payment Interface (UPI); Compensation
       deposited in interest bearing fixed deposit; Loss of interest to claimant;
       Digital payment transactions; Beneficial legislation; Website of the
       Ministry of Road, Transport and Highways (Transport Research
       Wing), Government of India; Number of accidents during 2018 to
       2022 with fatalities and persons injured; Lok Adalats; Insurance
       Companies; Era of technology; Artificial intelligence.

                                     Case Arising From
       CIVIL APPELLATE JURISDICTION: Civil Appeal No. 4299 of 2025
       From the Judgment and Order dated 04.09.2019 of the High Court
       of Punjab & Haryana at Chandigarh in FAO No. 3726 of 2017

                                 Appearances for Parties
       Advs. for the Petitioner:
       Ms. Shashi Kiran, Sr. Adv., Ms. Sadhana Sandhu, Dr. Rau P.S.
       Girwar, Ms. Archana Arora, Ms. K.T. Rau, Ms. Anju Sen, Adv.
       Adv. for the Respondents:
       Pradeep Gaur, Amit Gaur, Ms. Mansi, Rameshwar Prasad Goyal.

                      Judgment / Order of the Supreme Court

                                               Judgment

       Rajesh Bindal, J.

1.     Leave granted.
2.     Aggrieved by the order1 passed by the High Court2 in appeal,3 the
       claimant is before this Court seeking enhancement of compensation.



1     Dated 04.09.2019
2     High Court of Punjab and Haryana at Chandigarh
3     FAO No.3726 of 2017
[2025] 4 S.C.R.                                                            53

                    Parminder Singh v. Honey Goyal and Others


3.     The brief facts are that the appellant met with an accident on
       03.06.2014 when he was hit by a car bearing registration No.
       PB-03-X-0169 coming from the opposite direction. The appellant
       was driving his motorcycle. A criminal case was registered against
       the driver of the car. The appellant having suffered grievous
       injuries, resulting in his disability filed claim petition4. The age of
       the appellant at the time of the accident was 21 years. He was
       aiming to become veterinary doctor and pursuing his studies for
       that. The injuries suffered by him resulted in quadriplegia5. As a
       consequence of which he was declared 100% disabled as per the
       medical certificate issued by the Orthopedic Surgeon, Civil Hospital,
       Bathinda. He had incurred medical expenses of ₹2,66,000/- on his
       treatment. A lump sum amount of ₹2,00,000/- was awarded to the
       appellant on account of his 100% disability. The Tribunal6 in a very
       conservative estimate assessed the compensation payable to the
       appellant at ₹5,16,000/-.
4.     Aggrieved against the Award of the Tribunal, the appellant preferred
       appeal before the High Court. The compensation was enhanced
       from ₹ 5,16,000/- to ₹ 15,25,600/-. The High Court has taken the
       income of the appellant as ₹ 5,600/- per month to assess the loss
       of income and applied the multiplier of 18. Under the head ‘Loss of
       Income’, the High Court assessed the compensation as ₹12,09,600/-
       as against ₹2,00,000/- awarded by the Tribunal and this was the
       only modification by the High Court in the Award of the Tribunal.
       Still dissatisfied, the appellant is before this Court.
5.     Learned counsel for the appellant submitted that it is a case in which
       as a result of an unfortunate accident the appellant had suffered
       quadriplegia resulting in 100% disability. The income of the appellant
       has been assessed on the lower side. He was aiming to become
       a veterinary doctor for which he was pursuing his studies. He was
       a State Level player in Volleyball and had also undergone various
       other courses. The appellant was a young person of 21 years at the
       time of the accident. Now he will have to spend his entire life with
       100% disability as a result of which he has to take special diet and



4    MACT File No.84 of 2014
5    Paralysis of all four limbs (according to Oxford English Dictionary)
6    Motor Accident Claims Tribunal, Bathinda
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      also to engage an attendant to look after him. The High Court had
      failed to grant future prospects under the head ‘Loss of Income’.
6.    On the other hand, learned counsel for respondent no.3/United India
      Insurance Co. Ltd. submitted that already reasonable amount of
      compensation has been awarded by the High Court. No doubt the
      appellant had suffered disability but there is no ground made out
      for further enhancement of compensation. In the absence of any
      proof of income, the High Court has already assessed the income
      of the appellant at ₹5,600/- per month. There is no scope for further
      enhancement.
7.    Heard learned counsel for the parties and perused the relevant
      referred record.
8.    In the case in hand, basic undisputed facts on record are that the
      appellant was a young boy of 21 years of age at the time of the
      accident and having suffered quadriplegia the same resulted in his
      100% permanent disability. In the affidavit filed in his examination-
      in-chief, the appellant stated that he was learning the work for the
      Veterinary Doctor at Village Romana Ajit Singh, District Bathinda.
      He participated in 52nd International District School Games as a
      Volleyball player in October, 2006 when he was under 17 years
      of age. He had completed his course of pig farming from Punjab
      Agricultural University. In our opinion, as the appellant had suffered
      100% permanent disability he will have to live his entire life with
      that condition. As a result, he will require constant support of an
      attendant and a special diet.
9.    In our considered view, the income of the appellant has been taken
      on the lower side, which deserves to be enhanced. Considering the
      aforesaid credentials of the appellant who was a good sportsman and
      had certain technical qualification to his credit, in our opinion, taking
      his income merely at ₹5,600/- per month will not be appropriate. This
      was even less than the minimum wage for unskilled worker, which
      at that time was ₹6,447.75 per month w.e.f. 01.03.2014. For semi-
      skilled worker monthly minimum wage was ₹7,227.75 per month.
      Hence, we assess the income of the appellant as ₹7,500/- per month.
10. The High Court had rightly applied the multiplier of 18 but failed
    to grant future prospects under the head ‘Loss of Income’, which
    in the case of the appellant should be 40%. Hence, income after
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              Parminder Singh v. Honey Goyal and Others


     taking into account future prospects would be ₹10,500/- per month
     (₹7,500x1.4). The appellant being 100% disabled also deserves to
     be granted expense towards attendant, which in the case at hand
     has to be assessed as ₹5,00,000/- in lumpsum and compensation
     towards special diet is required to be enhanced from ₹25,000/- to
     ₹1,00,000/-. Considering the significant impact of the disability on the
     life of appellant, in our view, the amount towards pain and suffering
     is also required to be enhanced from ₹15,000/- to ₹1,00,000/-. In
     addition, looking to his condition, ₹2,00,000/- is awarded for future
     medical expenses and ₹2,00,000/- for loss of marriage prospects.
11. As far as the claim of the appellant regarding expenses incurred by
    him on physiotherapy is concerned, he has produced the receipts
    from one Dr. Satnam Saggu, who in his cross-examination was not
    able to support the receipts issued by him by way of counterfoils or
    the account books maintained by him. The Tribunal as well as the
    High Court has not awarded the appellant any compensation on
    that count. Though reliance on those receipts could not be placed
    in absence of clinching evidence but we can take judicial notice of
    the fact that physiotherapy would be required, therefore we deem it
    appropriate to award him lumpsum amount of ₹50,000/- on that count.
    Hence, the compensation awarded to the appellant is assessed in
    the following terms:

      Heads                                       Compensation (₹)
      Loss of Income                              (enhanced) 22,68,000
      [₹7,500 x 1.4 x 12 x 18]
      Medical Expenses                            2,66,000
      Attendant charges                           (awarded) 5,00,000
      Special Diet                                (enhanced) 1,00,000
      Pain & Suffering                            (enhanced) 1,00,000
      Expenses towards physiotherapy              (awarded) 50,000
      Future medical expenses                     (awarded) 2,00,000
      Marriage prospects                          (awarded) 2,00,000
      Total Compensation:                         36,84,000
12. For the reasons mentioned above, the appeal is allowed. The appellant
    is held entitled to receive total compensation of ₹36,84,000/-. The
    impugned award of the High Court is modified to that extent. The
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      amount so awarded shall carry interest at the same rate, at which
      it was awarded by the High Court on the enhanced compensation.
13. The respondent No.3/Insurance Company was held liable to pay the
    compensation as there was a valid insurance policy. The enhanced
    amount of compensation be calculated and transferred in the bank
    account of the appellant by the respondent No.3/Insurance Company
    within a period of six weeks from today. The particulars of the bank
    account along with the requisite document(s) in support thereof shall
    be furnished by the appellant with the respondent No.3/Insurance
    Company within a period of two weeks from the date of order.
    Needful shall be done by the respondent No.3/Insurance Company
    after verification of the same within four weeks thereafter along with
    up-to-date interest.
14. Before parting with the order we wish to express our concern regarding
    mode of payment of compensation in motor accident cases. The
    process can be streamlined by directly transferring the amount in the
    bank accounts of the claimants, so that the Insurance Companies
    and the claimants are saved from hassles of the court processes.
      14.1 As per the information available on the website of the Ministry
           of Road, Transport and Highways (Transport Research Wing),
           Government of India, the number of accidents during 2018 to
           2022 with fatalities and persons injured are as follows:

               Year       Accidents        Fatalities     Persons injured
               2018       4,70,403         1,57,593          4,64,715
               2019       4,56,959         1,58,984          4,49,360
               2020       3,72,181         1,38,383          3,46,747
               2021       4,12,432         1,53,972          3,84,448
               2022       4,61,312         1,68,491          4,43,366
            With the figures of the aforesaid accidents, insofar as the
            number of persons who died and injured is concerned, the
            claim petitions filed before the Tribunals are corresponding.
            The figures of filing of claim petitions and disposal thereof is
            neck to neck.
      14.2 As per response to an R.T.I. enquiry from Insurance Regulatory
           Development Authority of India, towards the end of 2022-23
           there were 10,46,163 claim cases pending throughout the
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              Parminder Singh v. Honey Goyal and Others


            country before the Tribunals (Source : Website of Press
            Trust of India). The number of cases increased from 9,09,166
            towards the end of 2019-20. Meaning thereby that there was
            an increase of 1,36,997 cases in a span of three years. This
            is besides the fact that large number of cases are regularly
            filed and decided.
     14.3 It is a matter of common knowledge that large number of
          motor accident cases are settled in Lok Adalats at the stage
          of Tribunal and some percentage at the appeal level. In the
          Lok Adalat recently held in the Supreme Court some matters
          were disposed of.
     14.4 As per the practice now followed, the cases in which Insurance
          Companies are held liable to indemnify the insured and pay
          compensation to the claimant(s), the amount is calculated
          and the same is either deposited by these companies in the
          Tribunal or in some small percentage of cases, transferred
          in the accounts of the claimants, if directed by the Tribunal
          in the award. Some of the companies are quick in depositing
          the compensation whereas some take time. In some cases,
          there may be intimation to the claimants regarding the deposit
          of the amount with the Tribunal, whereas in some there is no
          notice. The fact remains that these are the awards, which are
          not challenged.
     14.5 After the amount of compensation is deposited before the
          Tribunal, when the claimant(s) come to know about the same,
          they need to move an application for withdrawal of the same.
          Certainly, such an application will take some time in processing
          as the amount, which was deposited in the treasury has to
          be withdrawn from there. On an average the entire process
          takes about 15-20 days. Besides this, there may be delay in
          filing such application due to lack of knowledge of deposit.
          This process is besides the expenses to be incurred by the
          claimant(s). It is also a matter of common knowledge that with
          the increase in income level, the amount of compensation
          awarded by the Tribunal runs into lakhs of rupees and in some
          cases crores. The aforesaid process will certainly result in loss
          of interest to the claimant(s) for those 15-20 days and more
          in some cases, where the claimants had no knowledge about
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                deposit of amount. The process of aforesaid disbursement by
                the Tribunal has its own risks of error or omission, especially
                considering the huge amount involved therein. Still there may
                be cases where the amount may remain with the Tribunal
                because of lack of knowledge to the claimant and/ or non-
                withdrawal thereof.
       14.6 Apparently, no uniform practice is followed regarding deposit
            of the amount before the Tribunal, namely whether the amount
            will remain in government treasury or will be transferred in bank
            to be kept in interest bearing fixed deposit so that claimants do
            not suffer on account of interest for any delay in disbursement
            after deposit in Tribunal.
15. This is an era of technology, where now artificial intelligence is taking
    over. For conducting any bank transactions earlier we had to visit
    the bank branch in person and that too within the banking hours.
    Now all transactions can be affected 24x7, either sitting in the office
    or at home or even on mobile, while on the move. Practically the
    bank is in your mobile. Even cheques deposited in the banks for
    local clearance used to take couple of days. The outstation cheques
    took weeks together. Now, debits and credits in the accounts are
    instant with the help of technology.
       15.1 Our country has done wonders in digital payment transactions.
            As per the website of Ministry of Finance, Government of India,
            starting in the F.Y. 2013-14 from 220 crores, the transactions
            have increased to 18,592 crores in the F.Y. 2023-24. The
            value of the transaction has grown from ₹952 lakh crores
            to ₹3,658 lakh crores. Unified Payment Interface (UPI) is an
            indigenous developed digital payment system, which is easy
            to operate on a mobile. The UPI transactions have grown
            from 92 crores in the F.Y. 2017-18 to 13,116 crores in the F.Y.
            2023-24 at CAGR7 of 129%. The UPI transactions are likely
            to cross 20,000 crores in the F.Y. 2024-25. It is a matter of
            common knowledge that now under various schemes of the
            Government, funds are transferred to the beneficiaries directly
            in their bank accounts. As per the rough estimate, about 80%
            of the adult population in the country have bank accounts.


7     Cumulative Annual Growth Rate
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                Parminder Singh v. Honey Goyal and Others


16. A lot of matters come to the Court in which the amount is required to
    be paid to the litigants. Normal practice used to be, and still prevalent
    is to deposit the amount in court and thereafter to be withdrawn by
    the litigant. This process is not only followed in the cases where huge
    amount is involved but it is also seen prevalent even in the cases of
    payment of a small amount of maintenance to the wife, when fixed
    by the court either under Section 125 Cr.P.C. or under Section 12
    of the Domestic Violence Act, 2005 or any other statute. Withdrawal
    of the amount deposited in the court by any litigant certainly needs
    time and also expenses.
     16.1 This Court in the case of Haryana State Industrial
          Development Corporation v. Pran Sukh and others8 while
          considering a matter pertaining to payment of enhanced amount
          of compensation to the landowners, directed for transfering
          the same in their bank accounts. Relevant paras thereof are
          extracted below:
                   “With a view to ensure that the land owners are not
                   fleeced by the middleman, we deem it proper to issue
                   following further directions:
                   (i)    The Land Acquisition Collector shall depute officers
                          subordinate to him not below the rank of Naib
                          Tehsildar, who shall get in touch with all the land
                          owners and/or their legal representatives and inform
                          them about heir entitlement and right to receive
                          enhanced compensation.
                   (ii)   The concerned officers shall also instruct the land
                          owners and/or their legal representatives to open
                          saving bank account in case they already do not
                          have such account.
                   (iii) The bank account numbers of the land owners should
                         be given to the land Acquisition Collector within three
                         months.
                   (iv) The Land Acquisition Collector shall deposit the
                        cheques of compensation in the bank accounts of
                        the land owners.”


8   (2010) 11 SCC 175
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       16.2 Referring to the aforesaid judgement of this Court considering
            the fact that even at the stage of acquisition of land,
            compensation is required to be paid to the landowners, High
            Court of Punjab & Haryana in the case of Haryana State
            Industrial & Infrastructure Development Corporation Ltd. V.
            Smt. Krishna Rani & another 9 directed that even that amount
            should also be transferred in their bank accounts directly.
            Normal practice, which is followed in that process is that the
            compensation amount is deposited in the government treasury
            and the process of withdrawal is followed by the land owners.
            The relevant paras of that judgment are extracted below:
                      “Taking lead from the aforesaid directions issued
                      by Hon’ble the Supreme Court and finding that
                      harassment of the land owners is not only at the
                      stage when enhanced amount of compensation is to
                      be paid, rather, it is even at the stage when the award
                      by the Collector is announced as for the payment of
                      compensation, the land owners are to run after the
                      Patwaris or the officials in the office of the Collector.

                                xxx             xxx                xxx
                      …….. The land owners can be asked to furnish the
                      details of their bank accounts in response to the
                      notices issued to them under Section 9 of the Act and
                      in all undisputed claims, the amount should directly
                      be transferred by the Collector in the bank accounts
                      of the land owners immediately after announcement
                      of the award. This will not only save harassment of
                      the land owners but also time and energy of the
                      officials of the office of the Collector.
                      The aforesaid system should not only be restricted
                      to the State of Haryana, rather, the same system
                      should be followed even in the State of Punjab and
                      Union Territory, Chandigarh, where also the Collector
                      at the time of issuance of notices under Section 9
                      of the Act should ask the land owners to furnish


9     R.F.A. No.1492 of 2008 dated 08.04.2011
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              Parminder Singh v. Honey Goyal and Others


                the details of their bank account particulars and the
                Collector shall be duty-bound to directly transfer the
                amount of compensation in their bank accounts in
                all the undisputed cases.”
17. The case in hand pertains to the compensation awarded under the
    Motor Vehicles Act. The general practice followed by the insurance
    companies, where the compensation is not disputed, is to deposit
    the same before the Tribunal. Instead of following that process, a
    direction can always be issued to transfer the amount into the bank
    account(s) of the claimant(s) with intimation to the Tribunal.
     17.1 For that purpose, the Tribunals at the initial stage of pleadings
          or at the stage of leading evidence may require the claimant(s)
          to furnish their bank account particulars to the Tribunal along
          with the requisite proof, so that at the stage of passing of the
          award the Tribunal may direct that the amount of compensation
          be transferred in the account of the claimant and if there are
          more than one then in their respective accounts. If there is no
          bank account, then they should be required to open the bank
          account either individually or jointly with family members only.
          It should also be mandated that, in case there is any change
          in the bank account particulars of the claimant(s) during the
          pendency of the claim petition they should update the same
          before the Tribunal. This should be ensured before passing
          of the final award. It may be ensured that the bank account
          should be in the name of the claimant(s) and if minor, through
          guardian(s) and in no case it should be a joint account with
          any person, who is not a family member. The transfer of the
          amount in the bank account, particulars of which have been
          furnished by the claimant(s), as mentioned in the award, shall
          be treated as satisfaction of the award. Intimation of compliance
          should be furnished to the Tribunal.
18. In some cases, where the compensation is awarded to minor
    claimant(s) or otherwise, the Tribunal directs for keeping a certain
    percentage of the amount in a fixed deposit. Such a direction
    can always be issued in the award itself to be complied with
    by the concerned bank. When the amount is transferred by the
    Insurance Company in the account of the claimant(s), it shall be the
    responsibility of the bank to ensure that specified portion thereof
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      is kept in the fixed deposit. Compliance is to be reported by the
      bank(s) to the Tribunal.
19. It is also a fact that substantial amount of compensation in motor
    accident cases remains deposited in the Tribunal as the claimant(s)
    may not have approached the Tribunal for release thereof for various
    reasons. Delay for any reason in release of compensation in motor
    accident cases by the Tribunal to the claimant(s), where the amount
    is deposited in Tribunal, as directed, results in loss of interest to the
    claimant(s). In case the aforesaid process is followed, the gap would
    be bridged. The real object of the beneficial legislation, namely to
    compensate for the loss of earning member of the family or for the
    injuries suffered by the claimant(s), will be achieved and compensation
    can be disbursed without any delay.
20. We may add that directions are being issued for bank transfer of the
    amount of compensation in motor accident cases, but the Courts/
    Tribunals can always follow this process in any matter, whenever
    any amount is to be paid by one party to another, however, ensuring
    proper compliance.
21. The Registry is directed to send a copy of this order to (1) the
    Registrars General of all the High Courts for placing the same
    before the Chief Justice of the High Court for further circulation and
    compliance by the concerned Tribunals/Courts; and (2) the Directors
    of the National Judicial Academy and the State Judicial Academies.
22. Pending interlocutory applications (if any) shall stand disposed of.

      Result of the case: Appeal allowed.



      †
          Headnotes prepared by: Nidhi Jain