Deceased student’s monthly income assessed at ₹15,000, with 40% added for future prospects.

The appellants, parents of deceased Sohail, claimed that he died after being struck by a KSRTC bus while crossing the Jamkhandi–Mudhol Road on 29 March 2019.

The Tribunal partly allowed their claim and awarded ₹6,20,000, including ₹5,10,000 for loss of dependency, ₹80,000 for filial consortium, and ₹15,000 each for loss of estate and funeral expenses.

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

Whether the compensation awarded by the Tribunal was inadequate and required modification

What order should follow from the Court’s determination

Under Section 173(1) of the Motor Vehicles Act, 1988, an aggrieved party may appeal against a motor-accident compensation award.

In assessing dependency, the Court applied the principles in National Insurance Co. Ltd. v. Pranay Sethi, (2017) 16 SCC 680, including an addition for future prospects and a deduction for personal living expenses.

The Court also applied a 10% increase to the conventional heads of filial consortium, loss of estate, and funeral expenses.

The Court considered the deceased’s age, the circumstances of the accident, and the Central Government notification fixing monthly wages at ₹15,000, and assessed his monthly income at that amount.

Applying a 40% addition for future prospects, a 50% deduction for personal expenses, and a multiplier of 15, it calculated loss of dependency at ₹18,90,000.

It increased filial consortium from ₹80,000 to ₹88,000 and loss of estate and funeral expenses from ₹15,000 each to ₹16,500 each, resulting in total compensation of ₹20,11,000.

It modified the award to ₹20,11,000, with interest at 6% per annum from the date of the claim petition until payment, and directed the respondent to deposit the compensation and accrued interest before the Tribunal within eight weeks of receiving the certified judgment.