Doctrine of Res Ipsa Loquitur and potentiality of income for meritorious students govern motor accident compensation.

On February 19, 2017, Vinay Khurana and Prabhleen Kaur (both final-year B.E. students at NSIT, Delhi) died in a motor accident when their friend, Shivansh Malik, drove an offending vehicle (DL-3C-CE-9785) into a road divider rail.

The Motor Accident Claims Tribunal (MACT) awarded compensation, prompting cross-appeals: the Insurance Company sought reduction (challenging negligence and income assessment), while the claimants sought enhancement based on the deceased's high professional potential.

1. Whether negligence was established against the driver of the offending vehicle in the absence of a credible eyewitness.

2. Whether the MACT erred in assessing the notional income of the deceased students at Rs. 55,000 and Rs. 25,000 respectively, given their academic merit and placement offers.

3. Whether the interest rate of 9% p.a. awarded by the MACT was excessive.

4. Whether the claimants were entitled to enhanced "loss of consortium" for all dependents.

The court applied the doctrine of res ipsa loquitur to infer negligence from the circumstances of the accident.

It relied on Ranjeet v. Abdul Kayam Neb to hold that a filed chargesheet is sufficient evidence of negligence.

For income assessment of students, the court followed Navjot Singh v. Harpreet Singh and Vasanthi v. Adhiparasakthi Engg. College, emphasizing "potentiality of income" over minimum wages.

Determining compensation components followed Sarla Verma v. DTC regarding deductions and National Insurance Co. Ltd. v. Pranay Sethi for future prospects (40%), multiplier (18), and funeral/estate expenses.

Interest rates were guided by bank fixed deposit rates as per Kaushnuma Begum v. New India Assurance Co. Ltd.

The Court held that since the vehicle hit the divider with force and the driver offered no plausible rebuttal, negligence was proven via res ipsa loquitur and the existence of a chargesheet.

Regarding income for Vinay Khurana, the Court found the MACT's assessment speculative and instead relied on a concrete, pre-accident provisional offer from C-DOT (a Govt. entity) for Rs. 80,000 p.m., noting his high CGPA made qualification certain.

For Prabhleen Kaur, while she had no job offer, her merit as a Placement Coordinator and a prior internship stipend of Rs. 20,000 p.m. justified a conservative "potential income" estimate of Rs. 60,000 p.m.

The Court adjusted for income tax based on 2017-18 slabs.

On interest, the Court found 9% excessive for future awards but maintained it for the original amount due to the nine-year litigation delay, applying 6.75% only to the enhanced portion.

For Vinay Khurana: Income increased to Rs. 80,000 p.m.; total compensation enhanced to Rs. 1,07,71,800.

For Prabhleen Kaur: Income increased to Rs. 60,000 p.m.; total compensation enhanced to Rs. 84,32,600.

Consortium was increased to Rs. 40,000 per dependent.

The Court directed the enhanced amounts be deposited with 6.75% interest p.a. within four weeks, with specific directions for phased disbursal via Fixed Deposit Receipts.