A homemaker’s domestic-care contribution is valued at ₹30,000 monthly, with future prospects added.

The appellants— the deceased’s husband and two minor children—sought enhancement of compensation for her death in a road accident on 2 May 2023.

The Tribunal awarded ₹31,96,332, including ₹30,46,332 for loss of dependency, and directed the insurer to pay the award with 6% interest.

The claimants appealed, contending that the deceased’s salary certificate should have been considered and that the award should reflect her contribution as a homemaker and an increase in compensation under conventional heads.

Under Shishu Pal @ Shish Ram v. Surjeet, 2026 INSC 634, where a homemaker’s contribution is not reflected in conventional monetary income, ₹30,000 per month is to be treated as a basic minimum for loss of domestic care when the relevant heads of household contribution, maternal support and spousal support are met; the amount is subject to cumulative revision of 10% every three years.

Where the homemaker is also part of the workforce, domestic-care compensation is additional to proved monthly income.

The Court also applied the principles in National Insurance Co. v. Pranay Sethi, AIR 2017 SC 5157, including the 20% escalation to the conventional heads in this case.

The Motor Vehicles Act appeal was brought under Section 173(1).

The Court upheld the Tribunal’s use of multiplier 17, based on the deceased’s age of 26, and its deduction of one-third for personal expenses, given the husband and two children as dependants.

It found the Tribunal had rightly rejected the salary certificate because its author was not examined.

However, because the deceased was a homemaker and her husband and minor children had lost her companionship, care and maternal support, the Court assessed her monthly contribution at ₹30,000 under Shishu Pal.

It added 40% future prospects, deducted one-third for personal expenses and applied the multiplier of 17, producing ₹57,12,000 for loss of dependency/care.

It then applied a 20% increase to consortium, loss of estate and funeral expenses.

The appellants were awarded the enhanced sum of ₹26,95,668, with 6% interest per annum from the date of the petition until realisation; the insurer was directed to deposit it within six weeks.

The enhanced compensation was apportioned 20:40:40 among the husband and the two children.

The children’s shares were to be kept in fixed deposits until they attained majority, while 50% of the husband’s share was to be released and the remainder kept in fixed deposit for three years.