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The Gujarat High Court has held that income-tax returns cannot be rejected as fabricated merely on an insurer’s assertion, and that future prospects are not confined to people in permanent employment. In United India Insurance Co. Ltd. v. Pankajkumar Mahendrasinh Beravat & Anr., the court dismissed the insurer’s appeal and left the reported ₹12,95,280 compensation award in place. The ruling treats returns as relevant evidence, not as conclusive proof in every case.
What the Gujarat High Court decided
Justice J. C. Doshi decided the appeal in United India Insurance Co. Ltd. v. Pankajkumar Mahendrasinh Beravat & Anr., R/First Appeal No. 2637 of 2025. The insurer challenged the Motor Accident Claims Tribunal’s assessment of the claimant’s income and its award of future prospects. The High Court found no basis to interfere with the award. LiveLaw’s report identifies the decision as 2026 LiveLaw (Guj) 279.
CourtBook reports that the Tribunal awarded ₹12,95,280, with interest at 7% per annum from filing of the claim petition until realization. The reports available describe the award and its broad components, but do not provide enough detail to reconstruct the full calculation.
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The claimant, Pankajkumar Mahendrasinh Beravat, was reported to be a third-year civil-engineering diploma student who also worked as a civil contractor. He relied on income-tax returns for four financial years to support his earnings. CourtBook reports that he claimed income of about ₹28,000 a month; that figure is his reported claim, not an independently stated judicial finding.
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The insurer argued that a full-time student was unlikely to earn income and that the returns were fictitious. The High Court rejected the argument in the circumstances reported: income-tax returns are statutory documents relevant to income, including income from business or professional activity, and the insurer had not produced cogent or concrete evidence of fabrication or artificial inflation. The insurer had also not disputed the returns in its written statement, through evidence, or in cross-examination, according to LiveLaw.
As LiveLaw reports the court’s reasoning: “in absence of any cogent or concrete evidence in contrast demonstrating that the income-tax returns were fabricated or that the income disclosed therein was artificially inflated, the mere assertion that such returns were filed with a view to exaggerate the income cannot be accepted.” This is a rule against dismissing the documents on bare allegation; it does not make every return conclusive in a compensation claim.
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Future prospects are not restricted to permanent employees
The insurer also argued that future prospects should not be allowed because the claimant was not permanently incapacitated from his occupation. The High Court rejected that position, treating future prospects as an additional component of just and fair compensation and stating that the principle is not confined to people with permanent employment.
LiveLaw reports that the court relied on the Supreme Court’s decision in Meena Pawaia and Others v. Ashraf Ali and Others, (2021) 17 SCC 148. It also referred to the 2026 Supreme Court ruling in Rashmirekha Tripathi and Anr. v. The Branch Manager (Legal Claims), Shriram General Insurance Company Limited and Others in addressing income from independent business or professional work. CourtBook additionally names V. Pathmavathi v. Bharthi Axa General Insurance Company Limited.
The reports do not state the precise future-prospects percentage used in this award. They therefore support the principle that permanent employment is not a prerequisite, but not a universal percentage or a complete calculation formula.
Why the court criticized the appeal
Justice Doshi also cautioned against using a statutory appeal simply to re-argue issues already governed by binding precedent when no legal or factual error is shown. LiveLaw quotes the court as saying that the right of appeal “cannot be permitted to be exercised in a manner that results in abuse of the process of law.” The court connected unnecessary delay in motor-accident claims with the hardship faced by injured claimants and families seeking compensation.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.What the decision means for compensation claims
- For claimants: Returns may help establish income from salaried work, a business, or professional activity. Their significance will depend on the evidence in the particular case.
- For insurers: If returns are alleged to be fabricated or inflated, the reported decision underscores the need for concrete evidence and a properly developed challenge, rather than a bare assertion.
- For future-prospects arguments: The reported holding rejects a categorical bar based solely on the absence of permanent employment; it does not establish the rate payable in every claim.
- For the result here: The insurer’s appeal was dismissed, leaving the Tribunal’s reported award in place.
The available accounts are secondary reports, not the full court order. They do not establish paragraph numbers or the detailed calculation, so those should not be inferred from the reported outcome.
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