Absent reliable proof of higher earnings, compensation may be assessed using applicable minimum wages.

The appellants, the deceased Vishnu Sahu’s widow, minor daughter, brother and mother, challenged the award dated 22 January 2025 of the 2nd Motor Accident Claims Tribunal, Bilaspur, which granted compensation of ₹24,72,816 for his death in a motor vehicle accident on 23 August 2023.

They sought enhancement, contending that the Tribunal had wrongly assessed the deceased’s monthly income at ₹10,480 instead of the pleaded ₹30,000 from catering work.

Whether the deceased’s monthly income should have been assessed above ₹10,480 on the basis of the claim that he earned ₹30,000 from catering work.

Whether the Tribunal’s compensation award warranted appellate interference or enhancement.

The Court identified no specific statute or precedent as the basis for its decision.

It applied the principle that a claimed income must be supported by documentary or other reliable evidence; in the absence of such evidence, the Tribunal could assess income by reference to the applicable minimum-wage notification. The Court considered the minimum wage prescribed for an unskilled labourer at the time of the accident to be ₹10,480 per month.

The appellants’ assertion that the deceased earned ₹30,000 per month through catering work was unsupported by documentary or reliable evidence. The Tribunal had instead relied on the minimum wage applicable to an unskilled labourer at the relevant time, and the High Court found no material establishing a higher income.

It therefore found the Tribunal’s assessment and the resulting compensation fair and proper, with no legal or factual infirmity warranting interference.

The appeal was dismissed at the admission stage, with no order as to costs.