The Sikkim High Court has set aside a Motor Accidents Claims Tribunal (MACT) award of over ₹29 lakh, holding that the claimant failed to prove permanent disability through medical evidence.
Background of the Case
The case, The Branch Manager, New India Assurance Co. Ltd. vs. Gyandup Tshering Lepcha & Others, arose from a compensation claim filed after a road accident.
The MACT in Gangtok had earlier awarded ₹29,12,887 with 6% interest, concluding that the injured claimant suffered around 50% permanent disability based on the nature of injuries.
The insurance company challenged this finding, arguing that no disability certificate or medical proof supported such a conclusion and that compensation was calculated on assumptions rather than evidence.
Hearing the appeal, Justice Meenakshi Madan Rai closely examined medical records and witness testimony.
The Court noted that while the claimant had suffered serious injuries such as rib fractures, hip dislocation, and chest trauma the discharge summary did not indicate any lasting disability. It also recorded that the patient’s recovery was “uneventful.”
The bench found fault with the MACT’s approach, observing that disability had been presumed without proper medical certification.
“The MACT has erred in reaching a finding of 50% disability sans disability certificate or medical evidence,” the Court said.
The judge further remarked that injuries like rib fractures or a treated hip dislocation do not automatically result in permanent disability unless supported by medical proof.
The Court also questioned the reliability of a witness statement, calling parts of it “self-defeating” and inconsistent with basic medical understanding.
The High Court pointed out that compensation for loss of income or long-term disability cannot be granted unless the claimant proves inability to work through credible evidence.
It accepted the insurer’s argument that only actual medical expenses, supported by bills, could be awarded in the absence of proven disability.
On scrutiny, the Court found that valid medical expenses amounted to ₹1,14,147 not the higher amount considered by the MACT.
Setting aside the MACT award, the Court held that the claimant is entitled only to ₹1,14,147 towards medical expenses.
It directed the insurance company to pay this amount within one month, along with 9% interest from the date of filing of the claim petition. In case of delay, the interest would increase to 12% per annum.
The appeal was accordingly disposed of.
Case Details:
Case Title: The Branch Manager, New India Assurance Co. Ltd. vs. Gyandup Tshering Lepcha & Others
Case Number: MAC App. No. 16 of 2025
Judge: Justice Meenakshi Madan Rai
Decision Date: 16 April 2026
