A homemaker’s contribution may be valued at ₹30,000 monthly when calculating dependency compensation.

On 16 December 2023, Shamshad Hajaratali Jhare fell while alighting from a NWKRTC bus at Bailhongal bus stand after the driver moved the bus; she died during treatment on 21 December 2023.

Her husband and six children sought compensation, asserting that she earned income through milk vending and shepherding work and supported the family.

The Motor Accident Claims Tribunal awarded Rs. 23,15,589, including Rs. 18,40,800 for loss of dependency, and interest at 6% per annum.

The claimants appealed under Section 173(1) of the Motor Vehicles Act, 1988, seeking enhancement.

Under Sarla Verma v. Delhi Transport Corporation, the applicable multiplier is determined by the deceased’s age.

Under National Insurance Co. Ltd. v. Pranay Sethi, future prospects are added to the deceased’s income and an appropriate deduction is made for personal expenses.

The Court relied on Shishupal @ Shish Ram v. Surjeet for assessing the contribution of a homemaker: the decision provides for a composite amount for loss of domestic care where the relevant heads apply, and states that domestic-care loss may be additional where the homemaker also participates in the workforce.

The appeal was brought under Section 173(1) of the Motor Vehicles Act, 1988.

The Court accepted the post-mortem report as the reliable evidence of age, found the deceased to be 48 years old, and applied multiplier 13.

It considered that she cared for her family and also undertook income-generating work, and, applying Shishupal, assessed her monthly income at Rs. 30,000.

It added 25% for future prospects and deducted one-fifth for personal expenses, resulting in loss of dependency of Rs. 46,80,000 (Rs. 30,000 × 1.25 × 4/5 × 12 × 13).

The Court left undisturbed the Tribunal’s awards for consortium, loss of estate, funeral expenses and medical expenses.

The enhanced compensation carries interest at 6% per annum from the date of the petition until payment, excluding the 220-day delay in filing the appeal.

The Corporation was directed to deposit the enhanced amount with accrued interest before the Tribunal within eight weeks of receiving the certified copy of the judgment.