Future prospects in motor accident compensation referred to a larger Bench amid conflicting Supreme Court precedents.

Conflicting Supreme Court authorities on addition of income for future prospects in motor accident compensation created uncertainty, particularly on whether self-employed persons and fixed-wage earners are entitled to such addition. The Court noted divergent approaches in the line of decisions from Sarla Verma, Santosh Devi, Rajesh and Reshma Kumari, and held that authoritative uniformity was lacking. The controversy was therefore referred to a larger Bench for settlement of the law, and the matter was placed before the Chief Justice of India for constitution of an appropriate Bench.

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Issues: Whether the conflict in the decisions on addition of income towards future prospects required reference to a larger Bench.

Analysis: The decision examined the line of authorities on future prospects in motor accident compensation, including the principles in Sarla Verma, Santosh Devi, Rajesh, and Reshma Kumari. It noted that the later decisions reflected divergent views on whether and to what extent self-employed persons or those on fixed wages are entitled to addition towards future prospects. In view of the lack of authoritative uniformity on the issue, the matter was considered fit for consideration by a larger Bench.

Conclusion: The controversy was referred for determination by a larger Bench.

Final Conclusion: The matter was not finally decided on merits and was placed before the Chief Justice of India for constitution of an appropriate larger Bench.

Ratio Decidendi: Where conflicting co-equal or larger-bench decisions create uncertainty on a recurring compensation question, reference to a larger Bench is appropriate to secure authoritative settlement of the law.

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