Mere Disability Certificate not proof of Actual Disability in Accident Claims, says HC

Recently, in a significant ruling on the evaluation of disability claims in motor accident cases, the Gujarat High Court intervened after an insurance company challenged the refusal of a Motor Accident Claims Tribunal (MACT) to permit reassessment of a claimant’s disability. The Court examined whether tribunals can deny parties an opportunity to question the authenticity or accuracy of disability certificates relied upon to determine compensation. The Court emphasised that disability assessments forming the basis of compensation must withstand careful scrutiny and should be supported by credible and verifiable medical evaluation.

The case began when a claimant sought compensation before the MACT following injuries sustained in a vehicular accident. During the proceedings, a disability certificate indicating 90% disability was produced, though it had been issued by a doctor who had not treated the claimant. During testimony, the same doctor suggested that the disability could be considered 55% permanent disability of the whole body, raising questions about the accuracy of the earlier assessment.

The insurance company subsequently filed an application seeking a direction that the claimant obtain a disability certificate from a District Medical Board or authorised authority, relying on Supreme Court guidelines that emphasise uniform and credible medical evaluation. However, the Tribunal rejected this request, prompting the insurer to approach the High Court, challenging the order passed by the Tribunal.

Justice Hasmukh D. Suthar observed that although the Motor Vehicles Act is a beneficial legislation, tribunals must remain cautious when evaluating medical evidence and should not mechanically accept disability claims without proper scrutiny. The Court stressed that merely producing a disability certificate cannot conclusively establish the extent of disability and that tribunals must actively assess the credibility of such evidence.

Referring to Supreme Court precedents, including Raj Kumar v. Ajay Kumar and Anr. and Bajaj Allianz General Insurance Co. Ltd. v. Union of India, the Bench noted that disability certificates should ideally be issued by a District Medical Board in accordance with the Government guidelines issued in 2018 to ensure uniformity and reliability. Emphasising the duty of tribunals to verify medical claims, the Court observed that “mere production of the Disability Certificate or Discharge Certificate is not the proof of the physical or functional disablement.”

Finding that the insurer had disputed the certificate and sought reassessment, the Court held that the Tribunal ought to have allowed the insurer to lead rebuttal evidence and seek evaluation by a competent medical authority.

Consequently, the Court quashed the Tribunal’s order and permitted the insurer to move an application directing the claimant to appear before a Medical Board for proper disability assessment.

Case Title: Tata AIG General Insurance Co. Ltd. Vs. Sunil Ishwarbhai Panchal & Ors.

Case No.: R/Special Civil Application No. 3605 of 2025

Coram: Hon’ble Mr. Justice Hasmukh D. Suthar

Advocate for the Petitioner: Adv. Kirti S Pathak

Advocate for the Respondent: None

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