MACT Compensation Appellate Interference: Supreme Court Clarifies Law
The Supreme Court on Wednesday (March 18) clarified that appellate courts must not interfere with findings of fact recorded by the Motor Accident Claims Tribunal (MACT), particularly on issues such as disability assessment and loss of earning capacity, unless they first conduct a thorough reappreciation of evidence and record clear, cogent reasons.
In this context, a Bench of Justices Prashant Kumar Mishra and Sandeep Mehta emphasised that appellate courts must carefully reassess the evidentiary record before departing from the Tribunal’s conclusions.
MACT Compensation Appellate Interference in Context: Tribunal Award
In the present case, the dispute arose from a motor accident claim in which the claimant suffered severe injuries, including head trauma and cognitive impairment, resulting in 63% permanent disability. After evaluating the medical and other evidence, the MACT awarded compensation of ₹65.53 lakh.
Supreme Court Rejects Improper Appellate Interference
However, the High Court reduced the functional disability to 30% and consequently lowered the compensation, while failing to undertake a detailed analysis of the evidence. Aggrieved by this reduction, the claimant approached the Supreme Court.
Beneficial Object of Motor Vehicles Law
Upon consideration, Justice Sandeep Mehta, who authored the judgment, held that an appellate court cannot replace the Tribunal’s findings with its own conclusions without properly analysing the evidence.
More importantly, the Court ruled that a mere substitution of views, without adequate reasoning, violates settled principles governing appellate review.
Precedent Reinforced: Raj Kumar v. Ajay Kumar
At the same time, the Bench highlighted that the Motor Vehicles Act serves as a beneficial legislation aimed at ensuring expeditious relief and just compensation for victims of road accidents and their families.
Accordingly, the Court stressed that any interference with a well-reasoned MACT award must align with the statute’s objective of promoting social justice and must rest on sound judicial reasoning.
Compensation Enhanced to ₹97.73 Lakh
In addition, reaffirming the principles laid down in Raj Kumar v. Ajay Kumar, the Court reiterated that physical disability does not always equate to loss of earning capacity. Nevertheless, courts must justify any departure from medical evidence with clear and convincing reasons.
Ultimately, the Court enhanced the compensation from ₹35.61 lakh, as determined by the Madras High Court, to ₹97.73 lakh. In doing so, it substantially restored and expanded the approach originally adopted by the MACT.
Therefore, the Court allowed the appeal.
Case Title: R. Halle v. Reliance General Insurance Company Limited
Citation: 2026 INSC 261
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