An Aadhaar card alone is not conclusive proof of age for determining the applicable multiplier.

The appellants, parents of the deceased, sought compensation under Section 166 of the Motor Vehicles Act, 1988, for his death in a road accident on 19 September 2019.

The Tribunal awarded ₹13,06,648 with interest at 9% per annum, assessing the deceased’s monthly income at ₹8,660 and applying a multiplier of 17.

In their appeal, the claimants challenged the assessment of the deceased’s age and multiplier, and the amounts awarded under consortium and other conventional heads.

1. Whether the Tribunal’s assessment of the deceased’s age based solely on his Aadhaar Card was sustainable, and whether the multiplier should be revised.

2. Whether the compensation awarded under loss of dependency and consortium, and the total compensation, required enhancement.

Under Section 166 of the Motor Vehicles Act, 1988, the compensation awarded must be just and proper.

Saroj v. Iffco-Tokio General Insurance Company, 2024 SCC OnLine SC 3038, establishes that an Aadhaar Card is not, by itself, conclusive proof of date of birth.

Under National Insurance Co. Ltd. v. Pranay Sethi, (2017) 16 SCC 680, future prospects are added when calculating loss of dependency; Sarla Verma v. Delhi Transport Corporation, (2009) 6 SCC 121, governs the applicable multiplier and deduction for personal expenses.

Under Magma General Insurance Co. Ltd. v. Nanu Ram, (2018) 18 SCC 130, parents may receive parental consortium.

The Court upheld the Tribunal’s income assessment because the claimants had produced no documentary evidence supporting the higher income claimed; the notional monthly income of ₹8,660 was therefore retained.

However, the deceased’s age was supported by the father’s unchallenged testimony and the post-mortem report, both recording his age as 24; the Aadhaar Card alone could not determine his age.

Applying 40% future prospects, deducting 50% for personal expenses, and applying multiplier 18 resulted in loss of dependency of ₹13,09,392.

The Court also increased parental consortium to ₹40,000 for each parent, while retaining ₹15,000 each for loss of estate and funeral expenses.

The Court assessed total compensation at ₹14,19,392, an enhancement of ₹1,12,744 over the Tribunal’s award.

The enhanced amount carries interest at 9% per annum from the date of the claim petition until payment; the remaining terms of the Tribunal’s award were left undisturbed.