Chhattisgarh High Court
Transport, Maritime, and Aviation LawCivil Law

Enhanced compensation cannot be based on claimed income unsupported by cogent evidence.

UTTARA KUMARI vs KULDEEP SINGH

Chhattisgarh High CourtJUDGMENT: October 13, 20261 MIN READSOURCE JUDGMENT
Enhanced compensation cannot be based on claimed income unsupported by cogent evidence.. UTTARA KUMARI vs KULDEEP SINGH. Chhattisgarh High Court. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

Narayan Prasad Chandra died from injuries sustained in a motor vehicle accident on 27 September 2024.

Source reference: para. 1–2

His widow and son claimed that he worked as a mason and earned Rs.15,000 per month.

Source reference: para. 1–2

The Motor Accident Claims Tribunal assessed his monthly income at Rs.10,380, applying the minimum wage prescribed for an unskilled labourer, and awarded compensation of Rs.14,82,500.

Source reference: para. 1–2

The claimants appealed, seeking enhancement on the basis of the higher asserted income.

Source reference: para. 1–2
02

Issues

1. Whether the Tribunal erred in assessing the deceased’s monthly income at Rs.10,380 rather than Rs.15,000

Source reference: para. 2, 5

2. Whether the compensation award warranted enhancement or other interference by the High Court

Source reference: para. 1, 6
03

Law Applied

The Court applied the evidentiary principle that a claimed income must be supported by cogent and reliable evidence before it can be accepted in assessing compensation.

Source reference: no citation

Where the asserted earnings are not established, the applicable minimum-wage notification may provide a basis for determining income.

Source reference: no citation

The Court referred to the Labour Department’s minimum-wage notification, under which the prescribed wage for an unskilled labourer at the relevant time was Rs.10,380 per month.

Source reference: para. 5

No statute or precedent was cited.

Source reference: no citation
04

Reasoning

The claimants asserted that the deceased was a mason earning Rs.15,000 per month, but produced no cogent and reliable evidence establishing either his occupation-based earnings or income above the minimum-wage figure.

Source reference: para. 5–6

In the absence of such evidence, the Tribunal was entitled to rely on the relevant minimum wage of Rs.10,380 per month.

Source reference: para. 5–6

The High Court found the Tribunal’s assessment and resulting award fair and proper, with no legal or factual infirmity warranting interference.

Source reference: para. 5–6
05

Holding

The High Court held that there was no basis to reassess the deceased’s income at Rs.15,000 per month and no ground to enhance the compensation.

It dismissed the appeal and made no order as to costs.

Source reference: para. 7
Chhattisgarh High Court

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UTTARA KUMARIvsKULDEEP SINGH

Chhattisgarh High Court · October 13, 2026

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