In Prahlad Sahai v. Haryana Roadways, Supreme Court lays down principles for awarding prosthetic limb and maintenance costs in motor accident compensation
The Supreme Court has held that compensation in motor accident cases must cover the cost of prosthetic limbs and their maintenance. It said such compensation is necessary to restore accident victims, as far as possible, to a life of dignity.
In Prahlad Sahai v. Haryana Roadways & Anr., Civil Appeal No. 4642 of 2026 (arising out of SLP (C) No. 8756 of 2024), decided on April 21, 2026, a Bench of Justice J.B. Pardiwala and Justice K.V. Viswanathan allowed an appeal seeking enhanced compensation for injuries that resulted in amputation.
The appellant suffered a motor accident on May 2, 2007, when a Haryana Roadways bus hit his motorcycle. The accident led to the amputation of his right leg below the knee.
The Motor Accident Claims Tribunal awarded ₹8,73,211. Later, the Rajasthan High Court enhanced the amount to ₹13,02,043. However, the appellant approached the Supreme Court and sought further enhancement, including compensation for prosthetic limbs.
Appearing for the appellant, Advocate Anuj Bhandari argued that the earlier awards did not include any amount towards the cost of a prosthetic limb or its maintenance.
He relied on Mohd. Sabeer @ Shabir Hussain v. UPSRTC and argued that prosthetic limbs need periodic replacement and maintenance. Therefore, he submitted that compensation should take into account the claimant’s lifespan.
He further argued that an artificial limb usually requires replacement every five years. In addition, he urged the Court to adopt standardized principles for awarding compensation in such cases.
The appellant also sought a fresh calculation of income and future prospects. He claimed a monthly income of ₹6,000 and asserted that the injury had caused 100% functional disability.
On the other hand, Haryana Roadways and the insurance company opposed the plea for higher compensation. They argued that compensation must remain just and reasonable and should not become a windfall.
Further, the insurance company relied on government notifications prescribing lower rates for prosthetic limbs. It also disputed the income claimed by the appellant.
The Supreme Court identified the central issue as the jurisprudential basis for awarding compensation under the head of prosthetic limb.
At the outset, the Bench reiterated that Section 168 of the Motor Vehicles Act, 1988 requires courts to award “just” compensation. According to the Court, compensation must be neither a windfall nor a pittance.
The Bench then emphasized that prosthetic limbs are integral to restoring dignity and mobility to amputees. For that reason, it held that courts must treat them as essential and not optional.
The Court applied the principle of restitutio in integrum. It held that compensation should, as far as possible, restore the claimant to his original position.
Relying on precedents including State of Haryana v. Jasbir Kaur, Hardeo Kaur v. Rajasthan State Transport Corporation, Mohd. Shabir, and Chandra Mogera v. Santosh Ganachari, the Court laid down the following principles:
A prosthetic limb typically has a lifespan of five years.
Compensation should be calculated up to an assumed life expectancy of 70 years.
Claimants may choose reasonable prosthetic devices, including from private providers.
Government-notified rates cannot limit just compensation when those rates are inadequate.
The Court also rejected reliance on government-notified rates. It described those rates as “abysmally low” and held that the claimant’s reasonable requirements must guide the award of compensation.
On the issue of income, the Court accepted ₹6,000 per month as a reasonable income for a driver.
It also held that the appellant had suffered 100% functional disability. The Bench noted that he could no longer continue in his occupation because of the amputation.
Accordingly, the Court enhanced the compensation under multiple heads. It awarded ₹21,00,000 towards the cost of seven prosthetic limbs at ₹3,00,000 each.
In addition, it granted ₹5,00,000 towards maintenance costs.
The Court also enhanced compensation for loss of future income by ₹8,02,368, taking the total under that head to ₹16,12,800.
Further, it awarded ₹18,000 for loss of income during treatment and ₹2,00,000 towards litigation costs.
As a result, the total enhanced compensation came to ₹36,20,350, over and above the amount awarded by the High Court.
The Supreme Court directed the insurance company to pay the enhanced amount within four weeks. It further ordered that, if the company fails to do so, the amount will carry interest at 9% per annum.
With these directions, the Court allowed the appeal. However, it passed no order as to costs.
