Farmworker’s Electrocution Death: Chhattisgarh HC Raises Family’s Compensation From ₹4.5L To ₹12.88L, Using Minimum-Wage Income

In brief

The question

1. Whether the trial court’s lump-sum award of ₹4,50,000 should be enhanced by independently assessing just, fair and reasonable compensation on the evidence and applicable principles?

The court held

The appeal was allowed in part, and compensation was enhanced from ₹4,50,000 to ₹12,88,000.

It also directed

The enhanced amount carries interest at 9% per annum from the date the claim petition was filed until realization.

The trial court’s directions on liability and disbursement remain in force, except as modified; parties were directed to bear their own costs.

01Facts

Anusuiya Pradhan died by electrocution on 11 July 2021 after coming into contact with an electrified barbed-wire fence around an agricultural field.

¶ 3–5

Her husband and two children sought compensation, alleging negligence in maintaining the electrical installation and fencing.

¶ 3–5

The Principal District Judge awarded ₹4,50,000 with interest at 9% per annum.

¶ 3–5

The claimants appealed, principally seeking enhancement; the High Court confined its consideration to the quantum of compensation.

¶ 3–5, 11–15

02Issues

i.1. Whether the trial court’s lump-sum award of ₹4,50,000 should be enhanced by independently assessing just, fair and reasonable compensation on the evidence and applicable principles?

¶ 15–20

ii.2. Whether the deceased’s income, future prospects, personal-expense deduction and multiplier should be assessed by applying the principles in Pranay Sethi and Sarla Verma?

¶ 18–27

03Law Applied

Under Section 96 of the Code of Civil Procedure, 1908, the High Court exercised appellate jurisdiction over the decree.

¶ 1

Compensation must be just, fair and reasonable, having regard to proven income and relevant facts; Karnataka Power Transmission Corporation Ltd. v. Rekha, 2026 SCC OnLine SC 1545, drawing on Raman v. Uttar Haryana Bijli Vitran Nigam Ltd., (2014) 15 SCC 1, and Balram Prasad v. Kunal Saha, (2014) 1 SCC 384, was cited for this principle.

¶ 16

As no uniform formula was prescribed for electrocution cases, the Court used Sarla Verma v. Delhi Transport Corporation, (2009) 6 SCC 121, as guidance for dependency deductions and multiplier, and National Insurance Co. Ltd. v. Pranay Sethi, (2017) 16 SCC 680, for future prospects, without mechanically applying the Motor Vehicles Act formula.

¶ 19–21

Provisions in the judgment · 1 · Linked ones open on LawLens

Code of Civil Procedure, 1908 Section 96

04Reasoning

The trial court had adopted a lump sum without independently evaluating the evidence and relevant factors, requiring appellate reassessment.

¶ 15–18

Although the deceased’s actual earnings were not documented, her husband’s evidence that she worked as a labourer, together with her capacity to work, supported assessing income at the applicable minimum wage for an unskilled Zone C worker: ₹9,200 per month.

¶ 23–24

The Court placed her in the 41–45 age group and added 25% for future prospects, producing annual income of ₹1,38,000.

¶ 22, 25

Applying a one-third deduction for personal expenses and a multiplier of 14, it calculated the loss of dependency at ₹12,88,000.

¶ 26–28