Introduction:

In the case of Karamjit Singh v. Amandeep Singh & Anr. (2024 LiveLaw SC 1058), the Supreme Court of India delivered a significant ruling enhancing motor accident compensation by recognizing a carpenter as a skilled worker. The case revolved around Karamjit Singh, a carpenter who lost his right hand in a motor vehicle accident in 2014. While the Motor Accident Claims Tribunal initially awarded compensation of Rs. 6,83,982, which the High Court increased to Rs. 8,26,000, the Supreme Court further enhanced it to Rs. 15,91,625. The Court held that carpentry involves precision and training, distinguishing it from unskilled labour, and applied the minimum wages for skilled workers to calculate the compensation.

Arguments of Both Sides:

The appellant, Karamjit Singh, argued for an increase in compensation, emphasizing that carpentry is a skilled profession requiring training, manual dexterity, and expertise. He contended that the loss of his right hand severely impacted his ability to work, depriving him of his livelihood and resulting in significant pain and suffering. Since there was no documentary evidence of his income, he urged the Court to consider the minimum wages notified for skilled workers to ensure fair compensation. The appellant relied on precedents like Neeta v. Maharashtra SRTC (2015) 3 SCC 590 and State of Orissa v. Adwait Charan Mohanty 1995 Supp (1) SCC 470, which classified carpentry as a skilled trade. These judgments emphasized that carpentry demands specialized knowledge and manual dexterity, distinguishing it from unskilled labour.

The respondents, on the other hand, contended that in the absence of proof of income, the minimum wages applicable to unskilled workers should be used to calculate the compensation. They argued that the claimant did not produce any documents, such as tax returns or receipts, to substantiate his income as a carpenter. The respondents also maintained that the compensation awarded by the High Court was adequate given the circumstances of the case.

Court’s Judgment:

The Supreme Court, comprising Justice Sanjay Karol and Justice Manmohan, firmly rejected the respondent’s argument that the minimum wages for unskilled workers should be applied. The bench highlighted that carpentry is an inherently skilled profession requiring significant training, precision, and manual dexterity. Referring to the observations in State of Orissa v. Adwait Charan Mohanty and Neeta v. Maharashtra SRTC, the Court reaffirmed that a carpenter falls under the category of an artisan or skilled worker. The Court explained that carpentry involves constructing objects, beautifying spaces, and even building housing in certain contexts, tasks that a person without training cannot undertake with the required precision.

In the absence of direct evidence of the appellant’s income, the Court relied on the minimum wages for skilled workers as notified by the Office of the Labour Commissioner, Punjab, at the relevant time. By applying these wage rates, the Court calculated the loss of future earning capacity and enhanced the compensation to Rs. 15,91,625. The enhanced compensation also accounted for non-pecuniary damages such as pain, suffering, and loss of enjoyment of life due to the amputation of the appellant’s right hand.

The bench emphasized the broader implications of the judgment, recognizing the dignity of labour and the value of skilled professions like carpentry. It observed that failing to acknowledge the specialized nature of such trades would lead to unfair outcomes in cases involving motor accident compensation or other disputes.