Madras High Court
Civil LawInsurance Law

A ₹20,000 monthly notional income is appropriate for a 26-year-old accident victim in 2022.

LAKSHMI vs SENTHIL MURUGAN

Madras High CourtJUDGMENT: October 13, 20262 MIN READSOURCE JUDGMENT
A ₹20,000 monthly notional income is appropriate for a 26-year-old accident victim in 2022.. LAKSHMI vs SENTHIL MURUGAN. Madras High Court. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The appellant, the deceased Manikandan’s mother, sought compensation under Section 166 of the Motor Vehicles Act, 1988, following his death from injuries sustained in a motorcycle collision on 8 April 2022.

Source reference: p. 2

She claimed that he was 26 years old, worked as a hotel master and occasional driver, and earned ₹30,000 per month.

Source reference: pp. 2–4

The Motor Accident Claims Tribunal found the accident was caused by the offending motorcycle and awarded ₹29,11,925, including ₹27,13,200 for loss of dependency, using a monthly income of ₹19,000.

Source reference: pp. 2–4

The claimant appealed under Section 173 of the Act, seeking enhancement; the insurer did not appear in the High Court.

Source reference: pp. 1, 5
02

Issues

1. Whether the Tribunal’s assessment of the deceased’s monthly income at ₹19,000 was inadequate and should be enhanced for calculating loss of dependency.

Source reference: pp. 5–7

2. Whether the compensation awarded under the other heads required modification.

Source reference: p. 8
03

Law Applied

The claim was brought under Section 166 and the appeal under Section 173 of the Motor Vehicles Act, 1988.

Source reference: pp. 1–2

Under National Insurance Company Limited v. Pranay Sethi, 2017 (2) TNMAC 609 (SC), future prospects are added to income in accordance with the deceased’s age and employment status; the Court applied an addition of 40% for the deceased, aged 26.

Source reference: p. 6

Under Sarla Verma v. Delhi Transport Corporation, 2009 (2) TNMAC 1 (SC), the applicable multiplier for the deceased’s age was 17.

Source reference: p. 7

The Court also deducted 50% of the deceased bachelor’s income for personal and living expenses.

Source reference: p. 7
04

Reasoning

Although the claimant asserted that the deceased earned ₹30,000 per month, the evidence did not substantiate that amount.

Source reference: p. 6

The Court nevertheless considered the Tribunal’s notional income of ₹19,000 inadequate for an accident in April 2022 and increased it to ₹20,000 per month.

Source reference: p. 6

Applying 40% for future prospects, deducting 50% for personal expenses because the deceased was a bachelor, and using a multiplier of 17, the Court calculated loss of dependency at ₹28,56,000.

Source reference: p. 7

It found no basis to alter the awards under the other heads.

Source reference: p. 8
05

Holding

The appeal was allowed.

The total compensation was enhanced from ₹29,11,925 to ₹30,54,725, with interest at 7.5% per annum from the date of the claim petition until deposit, subject to the exclusion of the 37-day delay period and credit for amounts already deposited or withdrawn.

Source reference: pp. 8–9

The insurer was directed to deposit the amount, with interest and costs, within six weeks; the Tribunal’s other disbursement directions remained unchanged, and the appellant was directed to pay any court fee due on the enhanced compensation.

Source reference: p. 9
06

Acts & Sections Cited

2 provisions across 1 statute referred to in this judgment. Each provision opens on LawLens.

Motor Vehicles Act, 19882

Madras High Court

Original Court PDF

LAKSHMIvsSENTHIL MURUGAN

Madras High Court · October 13, 2026

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