The Andhra Pradesh High Court has held that when a damaged vehicle is repaired using new spare parts, the actual cost of those parts should ordinarily be reimbursed without deducting depreciation. The Court also ruled that the owner of a damaged commercial vehicle can claim compensation for the loss suffered during the period the vehicle remained off the road for repairs.
Justice A. Hari Haranadha Sarma partly allowed an appeal filed by a tractor owner and enhanced the compensation awarded by the Motor Accident Claims Tribunal (MACT) from ₹41,400 to ₹1,21,266, with interest at 6% per annum.
Background of the Case
The appeal arose from an accident that occurred on 19 April 2008, when the claimant's tractor and trailer were allegedly parked near Silpa Weigh Bridge on National Highway-18 at Nandyal. According to the claimant, a lorry was driven in a rash and negligent manner and collided with the stationary tractor and trailer, causing substantial damage.
The claimant stated that he spent ₹70,566 on tractor repairs and ₹35,700 on trailer repairs. Although he sought compensation of ₹1.5 lakh, the MACT awarded only ₹41,400, relying largely on a surveyor's assessment that deducted depreciation from the repair cost. Challenging the adequacy of the award, the claimant approached the High Court.
Court's Observations
The High Court closely examined the evidence, including repair bills, witness testimony and the surveyor's report. It found that the repair bills for the tractor and trailer represented separate expenses and that there was no evidence suggesting they were fabricated or overlapping. Witnesses who carried out the repairs also confirmed that new spare parts had been fitted.
The Court noted that even the surveyor had acknowledged that depreciation had been deducted in his report despite new parts being used during repairs. The surveyor further accepted that the tractor would normally generate income and that its non-use during repairs resulted in financial loss.
Referring to earlier judicial precedents, including a Full Bench decision of the Kerala High Court, Justice Sarma observed that deducting depreciation from the cost of new spare parts would effectively reduce the claimant's actual loss.
The judgment observed:
“One cannot expect a person to repair his vehicle with old spare parts.”
The Court explained that replacing damaged components with new ones merely restores the vehicle to a roadworthy condition and should not result in a reduced compensation merely because new parts were installed.
Compensation for Loss of Vehicle Use
The High Court also dealt with the claim for loss caused by the vehicle remaining unavailable during repairs.
Relying on previous Andhra Pradesh High Court precedent, the Court held that compensation is not confined to physical damage alone. Where a commercial vehicle cannot be used because it is undergoing repairs, the owner may also be compensated for the resulting incidental loss arising from its non-availability.
Applying this principle, the Court awarded ₹15,000 towards the inability to use the tractor for one month, calculated at ₹500 per day, in addition to the repair expenses proved through documentary evidence.
Court's Decision
Allowing the appeal in part, the Andhra Pradesh High Court enhanced the compensation from ₹41,400 to ₹1,21,266, together with 6% annual interest from the date of filing of the claim petition until realization.
The Court directed that the vehicle owner and the lorry owner remained jointly and severally liable, while clarifying that the insurer would satisfy the award in accordance with the insurance policy.
The Insurance Company was directed to deposit the enhanced compensation within one month, either directly into the claimant's bank account or before the MACT, depending upon compliance with the Court's directions.
There was no order as to costs.
Case Details
Case Title: G. Jayarami Reddy v. A.V.N. Muralimohan & Another
Case Number: M.A.C.M.A. No. 833 of 2012
Judge: Justice A. Hari Haranadha Sarma
Decision Date: 01 July 2026
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