Adult siblings are legal representatives entitled to compensation upon establishing dependency in a joint family.

The Respondents (Claimants) filed a petition under Section 166 of the Motor Vehicles Act, 1988, seeking compensation for the death of their brother in a motor accident occurring on the night of May 28–29, 2022

The Motor Accidents Claims Tribunal (MACT), Gangtok, awarded ₹4,22,21,125

The Appellant Insurance Company challenged the award, contending that the Respondents, being adult siblings with their own income, were not dependents

The Appellant further argued that because the deceased’s wife and children also perished in the accident, he should be treated as a "bachelor" for the purpose of deducting 50% toward personal expenses rather than 1/3rd

The Appellant contested the reliance on Income Tax Returns (ITR) without supporting bank statements and challenged the inclusion of litigation costs

1. Whether adult siblings qualify as "legal representatives" entitled to compensation and whether they established dependency

2. Whether the deceased should be treated as a bachelor for personal expense deduction because his immediate family died in the same accident

3. Whether the MACT erred in its calculation of compensation regarding income, conventional heads, and litigation costs

The Court applied the definition of "legal representative" from N. Jayasree v. Cholamandalam MS General Insurance Co. Ltd. and Sadhana Tomar v. Ashok Kushwaha, which mandates a liberal interpretation for benevolent legislation

Regarding personal expense deductions, the Court followed Sarla Verma v. Delhi Transport Corporation, which prescribes a 1/3rd deduction for married persons and 50% for bachelors

For non-pecuniary damages, the Court relied on National Insurance Co. Ltd. v. Pranay Sethi, establishing the heads of "loss of estate," "loss of consortium," and "funeral expenses" with a 10% enhancement every three years

It further integrated Magma General Insurance Co. Ltd. v. Nanu Ram regarding "filial consortium"

United India Insurance Co. Ltd. v. Satinder Kaur, which held that "loss of love and affection" is comprehended within "loss of consortium"

The Court dismissed the Appellant’s "unseemly" argument that the deceased became a bachelor due to the simultaneous death of his family, holding that his status at the time of the accident remained "married," justifying a 1/3rd deduction

On dependency, the Court found that the Respondents proved they lived in a joint family and were supported by the deceased, a claim the Appellant failed to decimate during cross-examination

The Court accepted the ITR as valid evidence of income since the Appellant provided no evidence to the contrary

Regarding the quantum, the Court struck down the ₹25,000 litigation cost and ₹20,000 transportation cost as lacking a legal foundation in Supreme Court precedents

It recalculated the conventional heads by applying the 10% triennial enhancement required by Pranay Sethi, increasing funeral expenses and loss of estate to ₹16,500 each and filial consortium to ₹1,32,000 total (₹44,000 per sibling)

It held that adult siblings are legal representatives entitled to claim compensation if dependency is established

The Court ordered the Appellant to pay the amount with 6% interest per annum within one month; failure to do so results in an increased interest rate of 9% per annum from the date of the claim petition

The award is to be divided equally among the three Respondents