Madras High Court
Transport, Maritime, and Aviation LawCivil Law

A reasonable notional income assessment based on education and age warrants no appellate interference.

The Managing Director, vs M. Dhandapani,

Madras High CourtJUDGMENT: September 28, 20262 MIN READSOURCE JUDGMENT
A reasonable notional income assessment based on education and age warrants no appellate interference.. The Managing Director, vs M. Dhandapani,. Madras High Court. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

Aravindan, aged 21 and holding a Diploma in Mechanical Engineering, died when the two-wheeler on which he was a pillion rider collided with a T.N.S.T.C. bus.

Source reference: paras. 2.1–2.3

His parents and sister sought compensation.

Source reference: paras. 2.1–2.3

The Tribunal attributed negligence to the bus driver and awarded ₹18,23,200 with interest at 7.5% per annum.

Source reference: paras. 2.1–2.3, 3.1, 4.1

The Corporation appealed, challenging liability and quantum, particularly the deceased’s monthly income, fixed at ₹11,000, and the award under loss of estate.

Source reference: paras. 2.1–2.3, 3.1, 4.1
02

Issues

Whether the Tribunal’s award of ₹18,23,200, including its assessment of the deceased’s income and compensation under other heads, required appellate interference

Source reference: para. 7; paras. 8.1–8.3
03

Law Applied

Section 173 of the Motor Vehicles Act, 1988 provides for an appeal against an award of a Motor Accident Claims Tribunal.

Source reference: prayer

In assessing the income of a deceased person who was not employed at the time of the accident, the court may make a reasonable estimate based on the available circumstances, including age, education and the year of the accident.

Source reference: para. 8.2

The Court also relied on National Insurance Company Ltd. v. Pranay Sethi for the applicable principles concerning future prospects and compensation under other heads.

Source reference: paras. 5.1, 8.3
04

Reasoning

The Court accepted that the deceased’s income had to be estimated because he was not shown to have been employed.

Source reference: paras. 8.1–8.2

Given his Diploma in Mechanical Engineering, age of 21 and the accident’s occurrence in 2018, it held that the Tribunal’s assessment of ₹11,000 per month was reasonable.

Source reference: paras. 8.1–8.2

It found no basis to interfere with the compensation under the other heads, which it considered consistent with Pranay Sethi, and rejected the Corporation’s contention that the award was excessive.

Source reference: para. 8.3
05

Holding

The Court dismissed the appeal and confirmed the Tribunal’s award.

It directed the Corporation to deposit the award amount with accrued interest at 7.5% per annum within six weeks of receiving a copy of the order, if not already deposited; the claimants may withdraw the amount according to the Tribunal’s apportionment.

Source reference: para. 9.1
06

Acts & Sections Cited

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

Motor Vehicles Act, 19881

Madras High Court

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The Managing Director,vsM. Dhandapani,

Madras High Court · September 28, 2026

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