Enhancement of Motor Accident Compensation Based on Revised Future Prospects and Standardized Conventional Heads.

The Appellant, widow of the deceased Sapke Nagesh (a Forest Guard earning Rs. 19,508/- per month), filed a claim petition following a fatal motor accident on December 6, 2015.

The deceased was traveling in a Bolero (C.G.-02/F/0080) driven rashly by Respondent No. 1, causing an accident resulting in immediate death.

The Motor Accident Claims Tribunal (MACT), Dantewada, awarded Rs. 23,66,216/- with 9% interest via award dated January 16, 2018.

Dissatisfied with the quantum, specifically regarding the calculation of future prospects and deductions, the Appellant moved the High Court for enhancement.

Whether the compensation awarded by the Tribunal was "just and proper" in accordance with established legal principles or required enhancement.

Whether the Tribunal erred in its methodology for calculating future prospects, personal deductions, and conventional heads.

The court applied Section 173 of the Motor Vehicles Act, 1988, regarding appeals.

It relied on *Hare Krushna Mahanta v. Himadari Sahu* (2025) and *Meena Devi v. Nunu Chand Mahto* (2023) to reiterate that the objective is "just" compensation, even if it exceeds the amount claimed in the petition.

For the computation of quantum, the court applied the standards set in *Sarla Verma v. DTC* (2009) and *National Insurance Co. Ltd. v. Pranay Sethi* (2017) regarding the 15%–50% addition for future prospects and specific multipliers.

It further utilized *Magma General Insurance Co. Ltd. v. Nanu* (2018) to grant "parental/spousal consortium" and mandated a 10% increase in conventional heads every three years.

The Court found the Tribunal’s assessment of the income at Rs. 19,508/- per month to be correct based on evidence.

However, the court identified errors in the application of *Pranay Sethi* guidelines: first, it applied a 50% addition for future prospects on the total income (annualized to Rs. 3,51,144/-) rather than the restricted "basic salary" approach used by the Tribunal.

Second, it corrected the deduction for personal expenses to 1/3 instead of the Tribunal’s 1/2, noting the claimant was the dependent wife.

Using the multiplier of 17 (appropriate for age 30), the loss of dependency was re-calculated at Rs. 39,79,632/-.

The Court also indexed the conventional heads—loss of estate, funeral expenses, and consortium—by 20% (10% every three years since the 2017 benchmark) to adjust for inflation as per *Pranay Sethi*.

Consequently, the Court awarded an enhancement of Rs. 16,97,416/- over the original award.

The enhanced amount carries an interest rate of 6% per annum from the date of filing the claim petition until realization, while the original interest rate of 9% on the Tribunal's awarded amount remained intact.