A compensation award will not be disturbed absent error, illegality, or perversity.

The claimants were awarded total compensation of ₹16,05,500, with interest at 9% per annum, for the death arising from a road accident.

The Tribunal held opponents Nos. 1 to 3 jointly and severally liable. The Insurance Company appealed under Section 173 of the Motor Vehicles Act, principally contending that the deceased’s income had been assessed too highly. The accident facts and the liability of the owner and insurer were not disputed in the appeal.

Whether the Tribunal’s assessment of the deceased’s income and resulting compensation warranted appellate interference.

Whether the compensation awarded by the Tribunal was just, fair and reasonable, notwithstanding that the award predated Pranay Sethi.

Section 173 of the Motor Vehicles Act provides for an appeal against an award of the Claims Tribunal, while Section 168 requires the Tribunal to determine just compensation.

In assessing compensation for death in a motor-vehicle accident, the court referred to Sarla Verma v. Delhi Transport Corporation, (2009) 6 SCC 121, on the methodology for determining compensation, and National Insurance Co. Ltd. v. Pranay Sethi, (2017) 16 SCC 680, concerning standardized heads of compensation.

The governing principle is that the award must be just, fair and reasonable; the court’s stated focus was on the substance of the overall compensation rather than strict correspondence with later-standardized heads.

The High Court reviewed the Tribunal’s compensation breakdown, including ₹14,35,500 for future loss of dependency and amounts under other heads, totalling ₹16,05,500.

Although the award predated Pranay Sethi and some heads did not strictly correspond with the later-standardized categories, the Court considered the overall award to substantially conform to the principles of just compensation.

It concluded that the Insurance Company had not demonstrated an error, illegality or perversity in the Tribunal’s findings that justified appellate intervention. The judgment does not separately set out a recalculation of the deceased’s income.

Any interim relief was vacated, and the Tribunal was directed to disburse the deposited amount to the claimants in accordance with law, after making a fresh disbursement order if required.