Compensation under conventional heads enhanced to ₹2,53,000 in fatal accident claim.

The claimants appealed under Section 173 of the Motor Vehicles Act, 1988, seeking enhancement of the compensation awarded for the death of Ramayan Prasad Sahu in a road accident on 19 August 2021.

The Claims Tribunal had awarded ₹19,28,032.

It assessed the deceased’s monthly income at ₹16,320, his age at 51, and applied 15% future prospects, a one-fourth deduction for personal expenses, and a multiplier of 11.

The claimants contended that the award, including compensation under the conventional heads, was inadequate; the insurer maintained that it was just and proper.

Whether the Tribunal’s compensation award required enhancement, particularly the amount awarded under the conventional heads

Section 173 of the Motor Vehicles Act, 1988, provides for an appeal against an award of the Claims Tribunal.

In assessing compensation, the Court relied on National Insurance Co. Ltd. v. Pranay Sethi, which addresses future prospects and conventional heads; Sarla Verma v. Delhi Transport Corporation, which provides principles for deductions and multiplier selection; and Magma General Insurance Co. Ltd. v. Nanu Ram, which recognizes consortium claims.

The Court treated the Tribunal’s assessment of income, future prospects, personal-expense deduction, and multiplier as proper, but held that the conventional-heads award required correction.

The Court found no basis to interfere with the Tribunal’s assessment of the deceased’s income, age, future prospects, one-fourth deduction, or multiplier.

It therefore retained the dependency compensation at ₹18,58,032.

However, it found the Tribunal’s ₹70,000 award under conventional heads inadequate and reassessed that component at ₹2,53,000, producing total compensation of ₹21,11,032.

The compensation was enhanced from ₹19,28,032 to ₹21,11,032, entitling the claimants to an additional ₹1,83,000, with interest at 6% per annum from the filing of the claim application until realization.

The remaining terms of the Tribunal’s award were left unchanged.

The Registry was directed to communicate the enhanced amount to the claimants in Hindi.