Compensation for death of a homemaker must include "loss of domestic care" at minimum notional income.

The appellant is the son of the deceased, Hajavva. On 27.07.2015, while Hajavva was a pillion rider on a motorcycle, the rider (Respondent No. 1) acted negligently, causing a collision with a buffalo.

Hajavva sustained grievous injuries and later succumbed on 01.09.2015.

The claimant, a minor aged 13 at the time of the accident, sought compensation.

The Motor Accident Claims Tribunal (MACT), Bilagi, awarded ₹18,71,517/-.

Dissatisfied with the quantum, particularly the calculation of the deceased homemaker's income, the claimant appealed for enhancement.

1. Whether the claimant is entitled to enhanced compensation based on the revised calculation of a homemaker’s notional income and "loss of domestic care".

The Court applied Section 173(1) of the Motor Vehicles Act, 1988, regarding appeals.

The court relied on the precedent set in Shishupal @ Shish Ram & Others v. Surjeet & Others (2026) INSC 634, which established that a homemaker’s contribution must be valued through a "loss of domestic care" head with a "stand-in" monthly income of ₹30,000/-.

The court utilized National Insurance Co. Ltd. v. Pranay Sethi (2017) for future prospects (40% for age 35).

The court applied Sarla Verma v. Delhi Transport Corp. (2009) for the multiplier (16) and personal expense deductions (1/3rd for 2-3 dependents).

The court utilized Magma General Insurance Co. Ltd. v. Nanu Ram (2018) for the 10% escalation on conventional heads.

The Court noted that the Tribunal failed to appropriately value the deceased’s role as a homemaker and sole provider for her minor son.

Following the Shishupal doctrine, the Court recognized that the household's functioning depended substantially on the deceased, warranting a "stand-in" monthly income of ₹30,000/- rather than lower notional rates.

Applying the Sarla Verma multiplier of 16 and adding 40% for future prospects, the Court calculated the gross dependency at ₹80,64,000/-. A deduction of 1/3rd was made for personal expenses (leaving 2/3rd as loss of dependency), resulting in ₹53,76,000/- for "loss of domestic care".

Conventional heads (Loss of Estate, Funeral Expenses, and Parental Consortium) were adjusted with a 10%+10% escalation as per the Magma principle.

Medical expenses of ₹7,36,317/- were maintained as per the Tribunal's finding.

The total compensation was enhanced to ₹61,97,017/-, granting an additional amount of ₹43,25,500/- over the Tribunal's award. The Respondent No. 2 (Insurer) was directed to deposit the enhanced amount with 6% interest per annum, excluding interest for a 1076-day delay period previously ordered.