Kerala High Court
Sameer vs V.M.Mymoon on 21 May, 2025
MACA 44/2017
1
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IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR. JUSTICE C.PRATHEEP KUMAR
WEDNESDAY, THE 21ST DAY OF MAY 2025 / 31ST VAISAKHA, 1947
MACA NO. 44 OF 2017
OPMV NO.1475 OF 2009 OF MOTOR ACCIDENT CLAIMS TRIBUNAL,
IRINJALAKUDA
APPELLANT/PETITIONER
SAMEER
S/O. LATE KAREEM, KALLOOPARAMBIL HOUSE, KHANNA
NAGAR DESOM & P O, MURINGOOR THEKKUMMURI VILLAGE,
MUKUNDAPURAM, TALUK
BY ADVS.
SRI.P.V.BABY
SRI.A.N.SANTHOSH
RESPONDENTS/RESPONDENTS 1 AND 3
1 V.M.MYMOON
OFFICER, CANARA BANK, BANERJI ROAD, KOCHI - 682018
2 UNITED INDIA INSURANCE COMPANY LTD
JOSE JUNCTION, M.G. ROAD, ERNAKULAM - 682035
BY ADV S.JAYASREE
THIS MOTOR ACCIDENT CLAIMS APPEAL HAVING COME UP FOR
ADMISSION ON3.4.2025, THE COURT ON 21.05.2025 DELIVERED
THE FOLLOWING:
MACA 44/2017
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JUDGMENT
Dated : 21st May, 2025 The petitioner in OP(MV).1475/2009 on the file of the Motor Accidents Claims Tribunal, Irinjalakuda, is the appellant. For the purpose of convenience, the parties are referred to as per their rank before the Tribunal.
2. According to the petitioner on 30.8.2009 at about 2.30 p.m. while he was riding a motorcycle, a Maruthi car bearing registration No.KL-8/Q-3564 driven by the 2nd respondent in a rash and negligent manner hit against the motorcycle of the petitioner and as a result of which he along with the pillion rider fell down and sustained serious injuries.
3. The 1st respondent is the owner and 3rd respondent is the insurer of the Maruthi car. According to the petitioner, the accident occurred due to the negligence of the driver of the offending vehicle. The quantum of compensation claimed in the O.P. is Rs.45,80,000/- limited to Rs.25,00,000/-.
4. The insurance company filed a written statement, admitting the accident as well as policy, but disputing the negligence on the part of the driver of the offending vehicle.
5. The evidence in the case consists of Exts.A1 to A29 marked from the side of the petitioner and Exts.X1 to X3. No evidence was adduced by the respondents.
6. After evaluating the evidence on record, the Tribunal found negligence on the part of the driver of the offending vehicle, awarded a total compensation of Rs.1160250/- and directed the insurer to pay the same. MACA 44/2017 3
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7. Aggrieved by the quantum of compensation awarded by the Tribunal, the petitioner preferred this appeal.
8. Now the point that arises for consideration is the following:
Whether the quantum of compensation awarded by the Tribunal is just and reasonable?
9. Heard Sri.P.V.Baby, the learned Counsel appearing for the petitioner/appellant, and Smt.S.Jayasree, the learned Standing Counsel for the 3rd respondent.
10. The Point: In this case the accident as well as valid insurance policy of the offending vehicle are admitted. In the accident the petitioner sustained serious injuries and later on his right leg above knee was amputated. The injuries sustained by him in the accident are:
1. 5x3 cm lacerated wound anterior aspect of middle 1/3 rd of right thigh.
2. Type III B open comminuted fracture right femur with bone loss.
3. Lacerated would 3x2 cm anterior medial aspect of promimal 1/3 rd of right leg with surrounding multiple abrasions and internal degloving injury.
4. 5x1 cm lacerated wound medial aspect of heel with avulsion of the heel pad etc.
5. Fracture of right tibia with internal degloving injury and segmental fracture right fibula.
11. The petitioner was treated as inpatient for a total period of 53 days in several spells. He also suffered chronic osteomyelitis of right tibia with persistent MACA 44/2017 4 2025:KER:34757 sinus. He also suffered from post operative infection. As per Ext.A25 disability certificate issued by a doctor his permanent physical disability was assessed as 25.30%. He was also examined by a Medical Board and Ext.X1 is the disability certificate issued by the Medical Board assessing his permanent physical disability at 25%. The functional disability of the petitioner taken by the Tribunal is also 25. The petitioner is a Driver-cum-Collection Agent by profession. In the claim petition the income claimed by him was Rs.6000/- per month and the Tribunal fixed his notional income at Rs.4500/-.
12. Along with I.A.1/2024 the petitioner produced several additional documents as Annexures A1 to A32, which includes the photographs of the petitioner showing the unhealed injuries sustained in the accident, the photographs taken after amputating his right leg above knee, photograph of his right leg with prosthesis, additional medical bills for Rs.10,31,539/-, discharge summaries issued from Lakeshore hospital etc., and Annexrrues A9, disability certificate issued by the District Medical Board, Ernakulam states that after his right leg was amputated above knee, his permanent physical disability is 80%.
13. In I.A.1/2024 the petitioner stated that in the accident he sustained fracture of thigh bone as well as both bones below knee on right leg, that the fractures were not properly united and hence, he was not able to use his right leg for day to day activities and that he was totally incapacitated and as such his functional disability comes to 100%. Further, according to the petitioner, the fracture on his right tibia never healed even in the year 2018, due to chronic osteomyelitis. When the infection MACA 44/2017 5 2025:KER:34757 to the right tibia became a threat to his life, causing severe pain due to chronic osteomyelitis, his right leg was amputated above knee on 31.10.2018. According to the petitioner, the root cause for amputation was chronic osteomyelitis, which is the result of the injuries sustained in the accident and as such, the learned counsel for the petitioner prayed for accepting the functional disability of the petitioner as 100%.
14. Serious objection was raised by the learned Standing Counsel against the additional documents produced as AnnexureA1 to A32. They have filed a counter affidavit. The main contention raised by the insurer is that the amputation was occasioned due to cancer of the bone and not due to the accident. According to them, amputation was effected not because of the chronic osteomyelitis but because of cancer. Further according to them, even if this Court finds that the petitioner is eligible for future medical expenses incurred by him it is to be restricted till 29.10.2018, the date of detection of cancer, which will come to Rs.1,63189/- and the rest of the medical expense incurred after detection of cancer cannot be allowed. According to them, they are liable to indemnify the petitioner only to the extent of injuries sustained in the accident. Therefore, the sum and substance of the contention raised by the learned Standing Counsel is that the amputation effected to the right leg of the petitioner was not because of the injuries sustained in the accident, but because of cancer which was detected subsequently.
15. Ext.A3 to 9, A15,A20 and A21 are the discharge summaries of the petitioner in respect of admission in different spells in 2009, 2010, 2011 and 2013. From those discharge summaries it can be seen that the petitioner suffered chronic MACA 44/2017 6 2025:KER:34757 osteomyelitis of right tibia with persistent sinus. He also suffered from post operative infection. Ext.A12 photographs of the petitioner shows severe disfigurement suffered by him. The fact that because of the injuries sustained in the accident on 30.08.2009 the petitioner suffered Chronic osteomyelitis on right tibia with persistent sinus is not in dispute.
16. In Annexure-A5 discharge summary issued from Lakeshore hospital states that the petitioner was admitted on 16.09.2018 and discharged on 21.09.2018. In the meantime, a surgery was conducted on 17.09.2018. The history of diagnosis as stated in Annecure-A5 is as follows:
"Mr.Sameer, a follow up case of Chronic Osteomyelitis (R) Tibia now presented to the outpatient department with complaints of pain and swelling over the (R) leg with occasional discharging sinus of 5 mths (months) duration. Clinical examination and radiological evaluation including CT Scan was suggestive of Reactivation of the Chronic Osteomyelitis (R) Leg. He was advised Reaming of Tibia, Excision of necrotic bone and antibiotic coated TENS nail insertion (R) Tibia. On
17.9.2018 under GA, the same was done. Post operative period was uneventful. Wound was inspected at regular intervals and change of dressing done. He is being discharged with advice to come for alternate day dressings on outpatient basis. Oral antibiotics are prescribed as per tissue culture and sensitivity report on the advice of the Microbioligist. At the time of discharge his wound are clean and he has no significant pain or any distal neurovascular deficit."
Details of the surgery performed on 17.09.2018 was stated in Annecure-A5 as follows:
MACA 44/20177
2025:KER:34757 "Under General anaesthesia the (R) lower limb prepared and draped. The sinus over the anteromedial aspect proximal tibia explored. The sinus tract excised and sent for culture and sensitivity."
Incision placed over knee along the previous surgical scar, patella tendon divided to expose the nail entry portal over the promixal tibia. The entry portal made with awl and the medullary canal opened with an ender nail. The medullary canal reamed with graded power reamer upto 12 mm. Another opening in the distal tibia made through a medial stab incision, using drill bit. Copious irrigation of the medullary canal done with saline. A TENS nail coated with antibiotic bone cement (Vancomycin), introduced intramedullary. The wound washed and closed in layers over a drain. The wound over the sinus left open. Sterile compression dressings applied."
17. In Annecure-A6 discharge summary the reason for recommending above knee amputation is stated as follows :-
"Mr.Sameer, a follow up case of reactivation of Chronic Osteomyelitis (R) tibia underwent Reaming of Tibia, Excision of necrotic bone and antibiotic coated TENS Nail insertion on 17.9.2018. During that surgery a soft tissue swelling of 1 cm in size was noted over the anterior aspect of tibia. The swelling was excised and sent for histopathological evaluation. This was reported as Synovial Cell Sarcoma. An Oncology consultation was sought for further management and as per their advice he was further evaluated with whole body PET Scan and Ultrasound guided FNAC of the inguinal lymphnode and metastasis ruled out. He was advised an Above knee Amputation (R) lower limb in view of chronic Osteomyelitis of tibia and Synovial Sarcoma of the leg. ....".
Accordingly on 31.10.2018, his above knee amputation was done.
18. In Ext.A5 it is specifically stated that occasional sinus discharge was MACA 44/2017 8 2025:KER:34757 due to re-activation of Chrronic osteomyelitis on the right leg. Now the question to be considered is, whether the Osteomyelitis sustained to the tibia is the cause for malignancy and subsequent amputation of the right leg of the petitioner ?
19. The learned Standing Counsel prayed for remanding the matter to the Tribunal for detailed enquiry in that respect. On the other hand, the learned counsel for the petitioner relied upon some medical authorities/ articles to substantiate his contention that Osteomyelitis is the root cause for the malignancy and subsequent amputation.
20. Relying upon an Article written by David C.Bury published in Am. Fam.Physician (Vol.104 No.4 October 2021) he would argue that the cause of malignancy and the subsequent amputation of the right leg of the petitioner was due to osteomyelitis. In the above article, the author states that :
"Osteomyelitis is an inflammatory condition of bone secondary to infection, in may be acute or chonic. Symptoms of acute osteomyelitis include pain, fever and edema of the affected site and patients typically present without bone necrosis in days to weeks following initial infection. Chronic Osteomyelitis develops after months to years of persistent infection and may be characterized by the presence of necrotic bone and fistulous tracts from skin to bone. Osteomyelitis is further classified by mechanism of infection as hematogenous or nonhematogenous. With hematogenous osteomyelitis, bacteria are seeded into bone secondary to a bloodstream infection and the condition is most common in children, older adults and immunocompromised populations. Nonhematogenous osteomyelitis occurs from direct inoculation in the setting of surgety or trauma or MACA 44/2017 9 2025:KER:34757 with spread from contiguous soft tissue and joint infections."
The different diagnosis of osteomyelitis includes soft tissue infection, gout, charcot arthropathy, fracture, malignancy, bursitis, osteonecrosis, sickle cell vasoocclusive pain crisis and SPHO syndrome (synovitis, acne, pustulosis, hyperostosis and osteitis. With regard to the treatment to be given to Osteomyelitis, the author says :
"Osteomyelitis treatment requires a multifaceted approach that may include antibiotics, surgical intervention and other modalities depending on multiple clinical factors, including clinical stage. Clinical staging guides decision-making when choosing specific surgical treatments and limits the need for amputation."
21. In the journal of Medical Case Reports [(2016) 10:215] with regard to "Squamous cell carcinoma in chronic Osteomyelitis : a case report and review of the literature", under the heading "Background", it is stated that :
"Chronic osteomyelitis is considered a great challenge for the orthopedist. The characteristic bone histology and the ability of bacteria to adapt to this particular microenvironment make these infections among the most insidious in the human body. Osteomyelitis is an inflammatin involving the osteorticular apparatus and its medullary canal that evolves in a progressive destruction of bone tissue. The characteristics of this phenomenon are bacterial colonies organised and protected by biofilm, a polymeric matrix the colonies excrete, often a polysaccharide. It is hard to breach this barrier, and antibiotics and disinfectants do their best to kill these shielded bacterial colonies. Further more, bacterial colonies enter a semidormant state that stretches pharmacodynamic effects of chemotherapies and the immune MACA 44/2017 10 2025:KER:34757 system, both specific and non-specific. In this report, we present a case of recurrent squamous cell carcinoma in a patient with chronic osteomyelitis for which surgical amputation of the limb was initially avoided."
22. The conclusion given in the above article is extracted below :-
"Malignant transformation in chronic osteomyelitis is a rare but unfavourable condition. Early diagnosis on the basis of information related to both clinical signs and imaging can lead to less invasive surgical treatments. Amputation is the definitive treatment of recurrent chronic osteomyelitis even in the absence of neoplastic transformation.
It should not be delayed, and the patient's compliance is of prime importance. Surgeons should be aware of the risk of tumor degeneration in patients with osteomyelitis and chronic wounds."
23. In the article "Squamous Cell Carnicoma Secondary to Chronic Osteomyelitis" by James E.Tozzi, Joseph M.Lane, Brian Hurson and Norman Higinbotham published in The Lowa Orthopaedic Journal (Vol.5, Pg 103) it is stated that :
"Squamous cell carcinoma (SCC) is an uncommon complication of chronic osteoymyelitis with an associated sinus tract...."
"......Majolin, in 1828, allegedly recognized malignant degeneration in burn scars; however, it remained for Hawkins, in 1835, to establish the association between chronic osteomyelitis and squamous cell carcinoma."MACA 44/2017 11
2025:KER:34757 ".......In a review of 2400 cases of osteomyelitis treated at the Massachusetts General Hospital, Benedict collected twelve cases of carcinoma, an incidence of 0.5 per cent. Ohe stressed the prophylactic treatment of osteomyelitis."
".......The tibia was the most frequently involved site, accounting for seven cases, with the femur involved in four patients. Other sits of involvement were: two metacarpals, one phalanx, one tarsus, one sacrum, and one humerus. Twelve patients gave a history of trauma and five other cases were attributable to hematogenous osteomyelitis."
"........The incidence of chronic osteomyelitis has decreased over the past fifty years and with it a decline in secondary squamous cell carcinoma. This change may be attributed to antibiotics and early aggressive surgical eradication of osteomyelitic foci. However, in spite of our best surgical attempts and recent technological advancements, there still remains a sizeable number of patients with chronic osteomyelitis. From this group, approximately 0.2 - 1.7 per cent will develop squamous cell carcinoma.
We must be aware of this uncommon but potentially fatal complication. We suggest that all patients with chronic draining osteomyelitis be observed closely for evidence of malignant degeneration......"
24. In the article "Malignant transformation in Chronic osteomyelitis"
by Diogo Lino Moura, Rui Ferreira and Antonio Garruco, the authors state that :
"Chronic osteomyelitis is a long-lasting and persistent bone infection caused by complex colonies of microorganisms involved in a matrix of proteinsand polysaccharides, the biofilm, which protects them from the body's immune system and the action of antibiotics. This condition MACA 44/2017 12 2025:KER:34757 can have an hematogenous origin, by contiguity to a focus of infection or by direction inoculation. Unlike hematogenous osteomyelitis, the incidence of osteomyelitis contiguous to a focus of infection originating from trauma, surgery, or implants has increased...."
"The exact mechanism of malignant transformation remains unknown. It is assumed that, in a multifactorial manner, the chronic inflammatory state behaves as a promoter in the complex process of carcinogenesis. Malignant transformation begins in the skin or epithelium of the fistula and infiltrate the adjacent tissues, including bone. The prevalence of malignant transformation in the setting of chronic osteomyelitis range from 1.6 % to 23%, and the most commonly affected bones are the tibia and femur. The most frequently observed malignant transformation is squamous cell carcinoma of the skin. The increase in fistulous drainage, as well as persistence, exophytic growth of an ulcer of mass can be warning signs for malignant transformation. All patients with ulcers and fistulas associated with chronic osteomyelitis should be frequently and carefully followed up and any characteristic alterations in a chronic wound should raise the suspicion of malignant transformation."
"......The definite and most frequently used surgican treatment in these situations, considering that the majority of patients have advanced disease, is the proximal amputation of the neoplasia......"
25. From the above authorities on medicine, produced by the learned counsel for the petitioner, it can be seen that chronic osteomyelitis may in the long run leads to bone infection, bone destruction and ultimately leading to formation of MACA 44/2017 13 2025:KER:34757 malignant tissues. Such malignant transforms are most commonly affected in tibia and humerous.
26. In the instant case, the respondents have no case that the petitioner sustained any other injuries in the meantime. Since even as per Annexures A3 to A9 and A15 discharge summaries, it is revealed that because of the injuries sustained in the accident, the petitioner suffered chronic osteomyelitis on right tibia with persistent sinus, there is every reason to believe the subsequent malignancy on his tibia and the resultant amputation of his right leg above knee are the result of the injuries sustained by him in the accident. Therefore, I find no merits in the argument advanced by the learned Standing Counsel that in this case there is no evidence to prove that the injuries sustained in the accident has resulted in amputation of his right leg. In other words, I hold that it was because of the injuries sustained in the accident, the right leg of the petitioner above knee was amputated.
27. Even as per the First Schedule to the Employees Compensation Act, amputation below hip with stump exceeding 12.70 cms in length measured from tip of great trenchanter but beyond middle thigh results in 70% loss of earning capacity. In the instant case the petitioner was a Driver-cum-Collectin Agent. Since his right leg above knee was amputated, his permanent physical disability as assessed by the District Medical Board as per Annexure A9 namely 80% is not on the higher side. Therefore, the permanent physical disability of the petitioner as assessed by the Medical Board in Annexure-A9 is accepted.
28. From Ext.A14 driving licence it is revealed that the petitioner was a MACA 44/2017 14 2025:KER:34757 driver cum-Collection Agent as claimed in the OP. Relying upon the decision of the Hon'ble Supreme Court in Manusha Sreekumar v. United India Insurance Company Ltd., 2022 (5) KLT OnLine 1024 the learned counsel would argue that the notional income of a driver in the State of Kerala in the year 2015 was fixed by the Apex Court at Rs.15,600/- and as such the notional income of the petitioner is to be fixed in tune with the above decision. In the decision in Fameessa and Ors. v. ALAVI and Ors. (MACA Nos.916/2016) and in Asokan v. The Manager, The New India Assurance Co.Ltd., (MACA 3543/2015), this Court has fixed notional income of a driver involved in an accident in the year 2008 at Rs.8500/-. Since in the instant case the accident occurred in the year 2009 and he is a driver by profession, the notional income of the petitioner is fixed at Rs.9000/-.
29. On the date of accident, the petitioner was aged 23 years. Therefore, 40% of the monthly income is to be added towards future prospects, as held in the decision in National Insurance Co. Ltd v. Pranay Sethi [(2017) 16 SCC 680] and the multiplier to be applied is 18 as held in Sarla Verma v. Delhi Transport Corporation, [(2009) 6 SCC 121]. In the above circumstances, the loss of disability will come to Rs.21,77,280/-.
30. Towards loss of earning, the tribunal has awarded only Rs.54,000/- being the income for 12 months (4500 x 12). Considering the nature of the injuries sustained and the percentage of disability suffered by the petitioner, the petitioner might have lost income at least for a period of 12 months. Therefore, towards loss of earning the petitioner is entitled to get a sum of Rs.1,08,000/- (9000 x 12 months). MACA 44/2017 15
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31. Towards the head 'pain and sufferings', the Tribunal has awarded Rs.80,000/-. Towards 'loss of amenities of life' Rs.40,000/- was awarded and towards 'extra nourishment' Rs.15,000/- was awarded. According to the learned counsel for the petitioner, the compensation awarded on those heads are on the lower side.
32. The petitioner sustained very serious injuries in the accident and was treated as inpatient for 53 days. Because of the injuries sustained, the percentage of disability suffered and the length of treatment undergone by the petitioner, I hold that the compensation awarded by the Tribunal on the heads 'pain and sufferings', 'loss of amenities of life' and 'extra nourishment' are on the lower side and hence they are enhanced to Rs.2,00,000/-, Rs.3,00,000/- and Rs.25,000/- respectively.
33. Along with I.A.1/2024 the petitioner has produced Annexures A9 to A30 medical bills together worth Rs.10,31,539/-. Since I have found that the right leg of the petitioner was amputated because of the injuries sustained in the accident, the petitioner is entitled to get refund of the above bills as part of the future medical expenses. Therefore, Rs.10,31,539/- is awarded towards future medical expenses, which will carry interest only from the date of this judgment.
34. The petitioner has produced Annexure-A31 tax invoice dated 3.6.2019 for Rs.44114/- for the accessories used for fixing prosthetic limb and Annexure-A32 tax invoice dated 5.6.2019 of a prosthetic limb for Rs.422385/- issued from Sai & Kaaizeen Prosthetic Solutions Pvt. Ltd. As per Annecure-A31 and 32, the price of one prosthesis and its accessories, together worth Rs.466499/- (422385 + 44114). On the basis of those tax invoices, the learned counsel prayed for awarding reasonable MACA 44/2017 16 2025:KER:34757 compensation towards the cost of prosthesis and it's periodical maintenance.
35. In the decision in Vivek G. v. National Insurance Company Ltd, 2023 KHC 2941, the Hon'ble Supreme Court has awarded a sum of Rs.20,00,000/- being the cost of four prosthesis and another Rs.6,00,000/- towards the cost of its maintenance to a 12 year old child, whose right leg was amputated in an accident in the year 2011. In the above circumstances, Rs.4,66,499/- claimed by the petitioner being the cost of one prosthesis is not on the higher side. Considering the fact that the petitioner was aged 23 at the time of the accident and the average life of a prosthesis is 5 years, he is entitled to get the cost of at least three prosthesis. In addition to the same, he needs expenses for its periodical maintenance. Therefore, towards the cost of prosthesis and its periodical maintenance expense, a consolidated amount of Rs.15,00,000/- is awarded, out of which Rs.10,00000/- will carry interest only from the date of this judgment.
36. No change is required, in the amounts awarded on other heads, as the compensation awarded on those heads appears to be just and reasonable.
37. Therefore, the petitioner/appellant is entitled to get a total compensation of Rs.53,76,069/- as modified and recalculated above and given in the table below, for easy reference:
Sl.
No. Head of Claim Amount awarded by Amount Awarded in
Tribunal (in Rs.) Appeal (in Rs.)
1 Loss of earnings 54000 1,08,000
2 Transportation expenses 20000 20000
3 Extra nourishment 15000 25000
MACA 44/2017
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4 Damage to clothing 1000 1000
5 Bystander's expenses 13250 13250
6 Medical expenses/future medical 6,00,000 10,31,539
expenses
7 Pain and sufferings 80000 2,00,000
8 Permanent disability & loss of 2,43,000 21,77,2801,77,280
earning power
9 Loss of amenities 40000 3,00,000
10 Disfiguration 50000 50000
12 Cost of prosthesis and its --- 15,00,000
periodical maintenance expense
Total 11,16,250 54,26,069
Amount enhanced 42,09,819
38. In the result, this Appeal is allowed in part, and Respondent No.3 is directed to deposit a total sum of Rs.53,76,069/- (Rupees fifty three lakh seventy six thousand sixty nine only), less the amount already deposited, if any, along with interest rate ordered by the Tribunal, from the date of the petition till deposit/realisation, (enhanced compensation will carry interest @ 8%. Out of which Rs.10,31,539/- will carry interest only from the date of this judgment), with proportionate costs, within a period of two months from today.
39. On depositing the aforesaid amount, the Tribunal shall disburse the entire amount to the petitioner, excluding court fee payable, if any, without delay, as per rules.
Sd/- C.Pratheep Kumar, Judge Mrcs/10.4.25 MACA 44/2017 18 2025:KER:34757 APPENDIX OF MACA 44/2017 PETITIONER ANNEXURES Annexure A1 THE PHOTOGRAPHS OF MY LEG WHICH ARE TAKEN BEFORE THE AMPUTATION Annexure A2 THE PHOTOGRAPHS OF MY LEG WHICH ARE TAKEN BEFORE THE AMPUTATION Annexure A3 THE PHOTOGRAPHS OF MY LEG TAKEN AFTER THE AMPUTATION OF MY RIGHT LEG Annexure A3(a) THE PHOTOGRAPHS OF MY LEG TAKEN AFTER THE AMPUTATION OF MY RIGHT LEG Annexure A4 THE X-RAY FILM OF THE RIGHT FEMUR OF THE APPELLANT TAKEN ON 03.08.2016 Annexure A5 THE DISCHARGE SUMMARY ISSUED FROM LAKESHORE HOSPITAL, KOCHI DATED21.09.2018 Annexure A6 THE TRUE COPY OF THE DISCHARGE SUMMARY ISSUED FROM LAKESHORE HOSPITAL, KOCHI DATED 24.11.2018 Annexure A7 THE TRUE COPYOF THE DISCHARGE SUMMARY ISSUED FROM LAKESHORE HOSPITAL, KOCHI DATED 25.01.2019 Annexure A8 7. THE DISABILITY CERTIFICATE ISSUED BY THE DISTRICT MEDICAL BOARD ERNAKULAM ASSESSING THE DISABILITY OF THE APPELLANT AFTER THE AMPUTATION OF HIS RIGHT LEG DATED 14.02.2019 Annexure A9 8. THE ORIGINAL MEDICAL BILLNO. VIVID 12419 DATED 11.09.2018 ISSUED BY VIVID IMAGING AND DIAGNOSTIC CENTER, KOCHI Annexure A10 THE ORIGINAL MEDICAL BILL NO. VIVID 124235 WITH DATED11.09.2018ISSUED BY VIVID IMAGING AND DIAGNOSTIC CENTER, KOCHI MACA 44/2017 19 2025:KER:34757 Annexure A11 THE ORIGINAL MEDICAL BILL NO. 082964 DATED 13.09.2018 ISSUED BY LAKESHORE HOSPITAL AND REASEARCH CENTRE LTD, KOCHI Annexure A12 THE ORIGINAL MEDICAL BILL NO.8384 DATED 13.09.2018LAKESHORE HOSPITAL AND RESEARCH CENTRE LTD, KOCHI Annexure A13 THE ORIGINAL MEDICAL BILL NO. 083972 DATED 15.09.2018 Annexure A14 THE ORIGINAL MEDICAL NO. IP7088 BILL DATED 21.09.2018 Annexure A15 THE ORIGINAL MEDICAL BILL NO. 088978 DATED24.09.2018 Annexure A16 THE ORIGINAL MEDICAL BILL NO.090832 WITH DATED 27.09.2018 Annexure A17 THE ORIGINAL MEDICAL BILL NO.091813 DATED29.09.2018 Annexure A18 THE ORIGINAL MEDICAL BILL NO. 092657 DATED01.10.2018 Annexure A19 THE ORIGINAL MEDICAL BILL NO.069642 WITH THE DATED06.10.2018 Annexure A20 THE ORIGINAL MEDICAL BILL NO.095363 DATED06.10.2018 Annexure A21 THE ORIGINAL MEDICAL BILL NO. 095600 DATED06.10.2018 Annexure A22 THE ORIGINAL MEDICAL BILLNO.099623 DATED 15.10.2018 Annexure A23 THE ORIGINAL MEDICAL BILL NO. 000494 DATED19.10.2018 Annexure A24 THE ORIGINAL MEDICAL BILL NO. 102340 DATED19.10.2018 MACA 44/2017 20 2025:KER:34757 Annexure A25 THE ORIGINAL MEDICAL BILL NO.102243 DATED19.10.2018 Annexure A26 THE ORIGINAL MEDICAL BILL NO.18210 DATED24.10.2018 Annexure A27 THE ORIGINAL MEDICAL BILL NO.
003053DATED21.11.2018 Annexure A28 THE ORIGINAL MEDICAL BILL NO. 084004 DATED24.11.2018 Annexure A29 THE ORIGINAL MEDICAL BILL NO. IP9745 DATED 24.11.2018 Annexure A30 THE ORIGINAL MEDICAL BILL NO. IP12210 DATED 25.01.2019 Annexure A31 THE ORIGINAL BILL NO SKA/INV/298 FOR THE ACCESSORIES USED FOR FIXING THE PROSTHETIC LIMP ISSUED FROM SAI AND KAAIZEEN PROSTHETIC SOLUTIONS PVT. LTD. KOCHI DATED 03.06.2019 Annexure A32 THE ORIGINAL BILL NO.SKA/INV/299 FOR THE ACCESSORIES USED FOR THE PROSTHETIC LIMP ISSUED FROM SAI AND KAAIZEEN PROSTHETIC SOLUTIONS PVT. LTD., KOCHI DATED 05.06.2019 statement STATEMENT