Summary
Compensation for a security officer’s amputation had to reflect functional loss of earning capacity through the multiplier method. Separate pecuniary awards for physical disability and future earnings duplicated the same loss. The Court recalculated that loss, added provision for replacement artificial limbs and fixed total compensation.
Issues
- How functional disability and future earnings should be assessed without double compensation.
Held
- Disability’s impact depends on the claimant’s work. Although the leg disability was 85%, the Court adopted 40% functional disability given reassignment to sedentary work and loss of promotion prospects. Salary with future prospects was Rs.21,000 per month; applying 40% and multiplier 15 yielded Rs.15,12,000. (¶ 5–7)
- The separate Rs.8 lakh physical-disability and Rs.13 lakh future-earnings awards duplicated pecuniary loss and were replaced by Rs.15,12,000. Other heads remained, with an additional Rs.2 lakh for artificial-limb replacement. (¶ 8–9)
Result
Appeals disposed of; total compensation Rs.23,26,835 with 8% annual interest from the claim petition date. No costs.