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

Conventional heads must be enhanced by 20% six years after *Pranay Sethi*.

SRI NARAYANASWAMY vs THE MANAGER DIRECTOR

Karnataka High CourtJUDGMENT: September 30, 20262 MIN READSOURCE JUDGMENT
Conventional heads must be enhanced by 20% six years after *Pranay Sethi*.. SRI NARAYANASWAMY vs THE MANAGER DIRECTOR. Karnataka High Court. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The appellants, parents of Maniraju, sought compensation for his death in a road traffic accident on 21 May 2024 involving a KSRTC bus.

Source reference: pp. 2–4

The Motor Accident Claims Tribunal partly allowed their claim and awarded Rs.18,57,032, with interest at 6% per annum.

Source reference: pp. 2–4

The parents appealed under Section 173(1) of the Motor Vehicles Act, 1988, seeking enhancement.

Source reference: p. 2

The appeal was delayed by 493 days; the High Court had directed that interest would not be payable for the delay period.

Source reference: pp. 2, 6–7
02

Issues

1. Whether the Tribunal’s assessment of loss of dependency should be enhanced by applying the applicable notional income for 2024.

Source reference: p. 4

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

Source reference: p. 5

3. Whether the appellants were entitled to interest on the enhanced compensation for the appeal’s delay period.

Source reference: pp. 6–7
03

Law Applied

Under the Motor Vehicles Act, 1988, compensation is assessed on the basis of the deceased’s income, applicable future prospects, personal-expense deduction and multiplier.

Source reference: p. 4

The Court applied the Karnataka State Legal Services Authority’s notional income of Rs.17,000 per month for 2024, added 25% for future prospects, deducted 50% for the deceased bachelor’s personal expenses, and applied multiplier 14.

Source reference: p. 4

Relying on *National Insurance Co. Ltd. v. Pranay Sethi*, AIR 2017 SC 5157, it applied a 20% increase to the conventional heads of consortium, loss of estate, and funeral expenses.

Source reference: p. 5

The appeal was considered under Section 173(1) of the Motor Vehicles Act.

Source reference: p. 2
04

Reasoning

The Court held that the Tribunal had used a lower notional monthly income of Rs.16,000 instead of Rs.17,000.

Source reference: p. 4

Applying 25% future prospects, a 50% deduction for personal expenses, and multiplier 14, it recalculated loss of dependency at Rs.17,85,000.

Source reference: p. 4

It increased the conventional-head awards by 20%, resulting in Rs.96,000 for consortium and Rs.18,000 each for loss of estate and funeral expenses.

Source reference: p. 5

The judgment’s discussion refers to medical expenses of Rs.16,032, while its compensation table lists Rs.67,032; the table gives a total award of Rs.19,84,032.

Source reference: pp. 5–6

The Court denied interest for the 493-day delay in filing the appeal, consistent with its earlier order.

Source reference: pp. 6–7
05

Holding

The appeal was allowed in part.

The appellants were awarded enhanced compensation of Rs.1,27,000, with interest at 6% per annum from the date of the claim petition until realization, excluding the 493-day delay period.

Source reference: pp. 6–7

The respondent was directed to deposit the enhanced amount with interest before the Tribunal within six weeks, and the appellants were entitled to receive it in equal shares.

Source reference: pp. 6–7
06

Acts & Sections Cited

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

Motor Vehicles Act, 19881

Karnataka High Court

Original Court PDF

SRI NARAYANASWAMYvsTHE MANAGER DIRECTOR

Karnataka High Court · September 30, 2026

Click to open original judgment

Original judgment, available to read, download and summarize on LawLens.in

Click to open original judgment