The Gujarat High Court has cautioned Motor Accident Claims Tribunals against blindly accepting disability certificates in accident compensation cases, warning that such documents can sometimes be produced without proper medical examination.
Justice Hasmukh D Suthar observed that certain doctors may issue “ready-to-use” disability certificates even without evaluating the person claiming injury. Because of this possibility, tribunals dealing with accident compensation must actively verify the authenticity and reliability of such documents instead of treating them as conclusive proof.
The Court referred to the precedent set in Raj Kumar v. Ajay Kumar, where the Supreme Court of India had earlier noted that some medical practitioners may provide disability certificates without conducting proper medical assessments.
Building on that principle, the High Court stressed that tribunals have a responsibility to examine the evidence carefully. When a disability certificate is placed on record, the tribunal cannot remain a passive observer; it must play an active role in evaluating whether the claim genuinely reflects the claimant’s physical condition.
While acknowledging that the Motor Vehicles Act, 1988 is intended to provide relief to victims of road accidents, the Court remarked that benevolent laws can sometimes be exploited. It noted that fabricated medical records or exaggerated claims occasionally surface in compensation proceedings, which makes careful scrutiny essential.
The observation came while the High Court allowed a plea filed by Tata AIG General Insurance Company Limited challenging a decision of the Motor Accident Claims Tribunal in Godhra.
The dispute arose from a compensation claim filed in 2017 by a man who said he suffered serious injuries to his right hand in a road accident. According to the claim, surgery resulted in the amputation of his index finger and removal of certain bones. A disability certificate placed before the tribunal assessed his disability at 90 percent.
The insurer contested the document, arguing that the certificate had been issued by a doctor who had not treated the injured person. It requested that the claimant’s disability be reassessed by a District Medical Board.
However, the tribunal rejected that request in 2024, prompting the insurer to move the High Court.
Setting aside the tribunal’s decision, the High Court held that merely producing a disability or discharge certificate cannot automatically establish the extent of a person’s disability. Instead, tribunals must assess “functional disability”—the real impact of the injury on the claimant’s ability to earn a livelihood.
The Court emphasised that compensation should be determined by examining how the injury affects the person’s overall earning capacity, rather than simply noting that the individual can no longer continue in the same occupation.
It also expressed concern about disability certificates being issued by doctors who had no role in treating the injured person and where unusually high percentages of disability are recorded without reference to recognised guidelines.
The High Court ultimately permitted the insurance company to seek a fresh direction from the tribunal requiring the claimant to appear before a District Medical Board for an independent evaluation.
The Court added that if the claimant fails to appear for the medical examination despite such an order, the tribunal would be free to draw an adverse inference while deciding the compensation claim.
