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The Supreme Court has substantially enhanced the compensation awarded to a minor girl who suffered catastrophic spinal injuries in a road accident at just six months of age, holding that courts must adopt a humane and realistic approach while assessing compensation for children with lifelong disabilities. A Bench of Justice Ujjal Bhuyan and Justice N.V. Anjaria increased the compensation from ₹45.40 lakh to ₹83.38 lakh and also raised the interest rate from 6% to 9% per annum.
Background of the Case
The case arose from a motor vehicle accident that occurred on June 16, 2015, when infant Shreejita Pattnaik was travelling with her parents in Odisha. Their car collided with a tanker coming from the opposite direction. The child suffered severe spinal cord and neurological injuries, resulting in permanent locomotor disability. Medical evidence placed her physical disability at 90%, with doctors stating that she would require lifelong treatment, assistance and rehabilitation.
The Motor Accident Claims Tribunal (MACT) initially awarded compensation of ₹30.12 lakh. The Orissa High Court later enhanced it to ₹45.40 lakh. Dissatisfied with the quantum, the child's mother approached the Supreme Court seeking further enhancement.
Court's Observations
The Supreme Court observed that claims involving children who suffer permanent disabilities cannot be assessed in the same manner as ordinary injury claims.
The Bench said,
“The present case concerns a child who has suffered permanent disability at a tender age and whose entire future stands altered on account of the injuries sustained in the accident.”
It added that courts must adopt “a realistic, humane and consistent” approach while determining compensation.
The Court reiterated that the Motor Vehicles Act is a beneficial legislation intended to provide "just, fair and reasonable compensation," emphasizing that compensation should neither become a windfall nor remain inadequate for the victim's lifelong needs.
A significant part of the judgment focused on the distinction between physical disability and functional disability. Although the child had been medically assessed with 90% permanent disability, the Bench held that her functional disability was effectively 100% because her injuries had completely destroyed her future earning capacity.
The judgment stated that the evidence showed she would remain dependent on others throughout her life and would be unable to independently perform normal daily activities or engage in any occupation.
The Court also held that in cases involving injured children, the multiplier of 18 should be applied while calculating future loss of earnings and attendant charges, following the approach adopted in recent Supreme Court precedents.
Reassessment of Compensation
Recalculating the compensation under various heads, the Court substantially increased the amount awarded for lifelong attendant charges, observing that the child would require continuous care and supervision.
The Bench fixed ₹25.92 lakh towards attendant charges after applying the multiplier method, saying this approach better reflects inflation, life expectancy and future care requirements.
The Court also enhanced compensation for pain, suffering, loss of amenities and marriage prospects to ₹25 lakh. Future medical expenses were doubled from ₹5 lakh to ₹10 lakh, while conveyance and special diet expenses were increased to ₹2 lakh.
Court's Decision
Allowing the appeal, the Supreme Court modified the High Court's judgment and enhanced the total compensation payable to ₹83,38,360 from ₹45,40,800.
The Court further directed New India Assurance Company Limited to deposit the entire enhanced amount with 9% interest per annum from the date of filing of the claim petition within six weeks before the Motor Accident Claims Tribunal, Cuttack, for disbursement in accordance with law.
No order as to costs was passed.
Case Details
Case Title: Gayatree Pattnaik for Shreejita Pattnaik v. Arundhati Sahoo & Anr.
Case Number: Civil Appeal No. 7067 of 2026
Judges: Justice Ujjal Bhuyan and Justice N.V. Anjaria
Decision Date: August 3, 2026
