The Supreme Court of India recently emphasized the authoritative value of disability certificates issued by a Medical Board. In a judgment authored by Justice Sanjay Karol, the Court ruled that the findings of such expert bodies cannot be reduced or altered without ordering a reassessment. The case involved a claimant who suffered severe injuries, resulting in a comatose state, after a motor vehicle accident.
The appellant, Prakash Chand Sharma, approached the Court challenging the Rajasthan High Court’s decision to reduce his compensation. Despite the Medical Board certifying a 100% permanent disability, both the Motor Accident Claims Tribunal (MACT) and the High Court assessed it at 50%. The courts questioned the absence of testimony from a neurosurgeon and doubted the certificate’s validity.
The Tribunal initially awarded the claimant Rs.16,29,465, which the High Court later enhanced to Rs.19,39,418. Dissatisfied, the claimant argued that the certificate, issued by a panel of experts, should have been given due weight. He further contended that if there were doubts about its accuracy, the courts should have ordered a reassessment rather than substituting their judgment.
Finding merit in the claimant's argument, the Supreme Court overturned the lower courts' decisions. The judgment stated,
“If the Tribunal had reason to doubt the medical certificate, the option available was to have the disability reassessed, but it could not have gone into the details of the determination of disability on its own.”
The Court highlighted that the Medical Board had unequivocally certified a 100% disability, noting that the claimant was entirely dependent on others for daily activities, could not stand or walk, and was catheterized. It further observed that the claimant's comatose condition was undisputed.
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The Supreme Court recalculated the compensation considering the 100% disability and attendant charges at Rs.48,70,000. Justice Karol emphasized,
“The opinion of the Medical Board, being an opinion of experts, must be treated with deference, especially when no reassessment has been conducted.”
Additionally, the Court criticized the insufficient allocation of Rs.2,00,000 for pain and suffering. It awarded an additional Rs.6,00,000 under this head, recognizing the immense physical and mental agony endured by the claimant and his family.
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Case Title: Prakash Chand Sharma vs. Rambabu Saini & Anr.
Injury Details: Multiple injuries resulting in a comatose state.
Key Issues: Disregard for the Medical Board’s 100% disability certification; inadequate compensation.
Supreme Court’s Decision: Reinstated 100% disability; awarded Rs.48,70,000 as compensation, with 7% annual interest.
The judgment underscores the necessity of respecting expert medical opinions and ensuring fair compensation for victims of motor accidents. It also serves as a cautionary precedent for lower courts to avoid arbitrary reassessment of expert findings without concrete evidence.
