Chhattisgarh HC Raises Compensation For Family Of Woman Electrocuted By Farm Fence From ₹4.5 Lakh To ₹11.96 Lakh

The appellants, the husband and sons of Kanchan Pradhan, sought compensation for her death by electrocution on 11 July 2021, alleging that current had passed into barbed-wire fencing around an agricultural field.

The Principal District Judge, Mahasamund, awarded ₹4,50,000 with interest at 9% per annum.

The plaintiffs appealed, principally challenging the quantum.

The High Court noted that the trial court had awarded a lump sum without independently assessing the evidence and relevant factors.

Under Section 96 of the Code of Civil Procedure, 1908, the High Court exercises appellate jurisdiction over the trial court’s decree.

Compensation for death by electrocution must be just, fair and reasonable, assessed with regard to proven income and relevant facts; no statutory formula specific to electrocution cases was identified.

The Court used Sarla Verma v. Delhi Transport Corporation, (2009) 6 SCC 121, for the dependency assessment, including personal-expense deductions and multiplier, and National Insurance Co. Ltd. v. Pranay Sethi, (2017) 16 SCC 680, for future prospects.

These principles were used as guidance, not by mechanically importing the Motor Vehicles Act, 1988 formula.

The Court found that the trial court had fixed compensation at a lump sum without assessing the evidence or relevant factors.

As documentary proof of income was absent, it assessed the deceased’s monthly income at ₹9,200, based on the applicable minimum wage for an unskilled worker.

Treating her as self-employed and placing her in the 46–50 age group, it added 25% for future prospects, deducted one-third for personal expenses and applied a multiplier of 13.

This produced an annual loss of dependency of ₹92,000 and total dependency compensation of ₹11,96,000.

The enhanced amount carries interest at 9% per annum from the date the claim petition was filed until realization.

The trial court’s directions on liability and disbursement remain unchanged, except to the extent modified by the High Court; the parties were directed to bear their own costs.