Chhattisgarh High Court
Transport, Maritime, and Aviation LawCivil Procedure and Evidence

Conventional compensation was enhanced by 10% in accordance with *Pranay Sethi*.

SMT. MADHURI PUJARI vs GURMIT SINGH

Chhattisgarh High CourtJUDGMENT: October 09, 20262 MIN READSOURCE JUDGMENT
Conventional compensation was enhanced by 10% in accordance with *Pranay Sethi*.. SMT. MADHURI PUJARI vs GURMIT SINGH. Chhattisgarh High Court. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The claimants, the widow and children of Tejram Pujari, appealed under Section 173 of the Motor Vehicles Act, 1988, seeking enhancement of compensation awarded for his death in a road accident on 4 August 2022.

Source reference: para. 8

The Claims Tribunal had awarded ₹46,26,532, assessing the deceased’s monthly income at ₹47,628, adding 15% for future prospects, deducting one-fourth for personal expenses and applying a multiplier of nine. It awarded ₹15,000 each for funeral expenses and loss of estate, and ₹1,60,000 for consortium.

Source reference: paras. 8, 12–13

The High Court condoned the 146-day delay and heard the appeal finally.

Source reference: paras. 1–7
02

Issues

1. Whether the Tribunal’s assessment of income, future prospects, personal-expense deduction and multiplier required interference.

Source reference: para. 12

2. Whether the compensation awarded under the conventional heads required enhancement.

Source reference: paras. 9, 13
03

Law Applied

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

Source reference: para. 8

The Court relied on *National Insurance Company Ltd. v. Pranay Sethi*, *Sarla Verma & Ors. v. Delhi Transport Corporation & Ors.*, and *Magma General Insurance Co. Ltd. v. Nanu Ram @ Chuhru Ram & Ors.* in assessing compensation, including conventional heads, future prospects, deductions and multiplier.

Source reference: para. 14

Applying *Pranay Sethi* to the accident date, the Court treated a 10% enhancement of the conventional-head amounts as permissible.

Source reference: para. 13
04

Reasoning

The Court found the Tribunal’s assessment of income and its application of 15% future prospects, a one-fourth deduction and multiplier nine to be just and proper, and therefore left those components undisturbed.

Source reference: para. 12

It recalculated the conventional heads by allowing ₹16,500 each for funeral expenses and loss of estate, and ₹1,76,000 for consortium for four claimants, increasing that component from ₹1,90,000 to ₹2,09,000 in total.

Source reference: para. 13; para. 14 (table)
05

Holding

The Court partly allowed the appeal and enhanced the total compensation from ₹46,26,532 to ₹46,45,532.

The additional ₹19,000 carries interest at 6% per annum from the date the claim application was filed until realization; the remaining terms of the Tribunal’s award remain unchanged.

Source reference: paras. 15–16

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

Source reference: para. 17
06

Acts & Sections Cited

1 provisions across 1 statute referred to in this judgment. Each provision opens on LawLens.

Motor Vehicles Act, 19881

Chhattisgarh High Court

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SMT. MADHURI PUJARIvsGURMIT SINGH

Chhattisgarh High Court · October 09, 2026

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