Future prospects apply to non-permanent earners, and compensation must align with standardized conventional heads.

The appellants, parents of the deceased Yogesh Mahant, filed a claim petition under Section 166 of the Motor Vehicles Act seeking compensation for their son’s death in a road accident on March 21, 2014

The deceased was a pillion rider on a motorcycle hit by a bus owned by respondent No. 1 and driven by respondent No. 2

The deceased was 24 years old and a final-semester Physiotherapy student

The Motor Accident Claims Tribunal (MACT), Solan, awarded ₹22,60,600 with 9% interest, based on a monthly income of ₹18,000 and 15% future prospects

The appellants approached the High Court seeking enhancement of compensation, arguing for a higher income base and higher future prospects

1. Whether the learned MACT erred in calculating the monthly income of the deceased and the percentage for future prospects

2. Whether the compensation awarded under conventional heads and the rate of interest require modification

The court primarily applied Section 173 of the Motor Vehicles Act regarding appeals

It relied on the principles of "just compensation" in beneficial legislation

It strictly followed the precedents of Sarla Verma v. Delhi Transport Corporation (2009) to determine the multiplier of 18 and the 50% deduction for personal expenses for a bachelor

It applied National Insurance Co. Ltd v. Pranay Sethi (2017) to award 40% future prospects for a non-permanent job holder under 40 years and to standardize conventional heads

It applied Magma General Insurance Co. Ltd. v. Nanu Ram (2018) regarding the entitlement to 'loss of consortium' for parents

The Court upheld the MACT’s assessment of the deceased’s monthly income at ₹18,000, rejecting the claimants' plea for ₹35,000, noting that the testimony regarding potential government salaries was speculative

The Court found the MACT’s grant of 15% future prospects legally unsustainable; per Pranay Sethi, since the deceased was 24, a 40% addition was mandatory, raising the monthly income to ₹25,200

After deducting 10% income tax (₹5,240 p.a.) and 50% for personal expenses, the annual dependency was fixed at ₹1,48,580. Applying a multiplier of 18, the loss of dependency was calculated at ₹26,74,440.

The Court further adjusted conventional heads (Funeral Expenses and Loss of Estate) to ₹15,000 each plus a 30% inflationary increase (10% every three years), and awarded ₹1,04,000 for filial consortium

The Court modified the interest rate to 7.5% per annum from the date of the petition until realization. The respondents are held jointly and severally liable to pay the enhanced amount.