Future prospects must be awarded even to non-earning deceased individuals to ensure just compensation.

On May 30, 2015, Nanjundaswamy (the deceased) was walking when he was hit by a Mahindra Bolero Jeep (KA-12-N-8992) driven in a rash and negligent manner.

He succumbed to his injuries on June 12, 2015.

The parents of the deceased filed a claim petition.

The Motor Accident Claims Tribunal (MACT) awarded ₹9,40,943 with 9% interest, holding the insurer liable.

The Insurance Company appealed (MFA 2193/2018) challenging the involvement of the vehicle and the deduction of 1/3rd for personal expenses.

The claimants appealed (MFA 3926/2018) seeking enhancement, specifically regarding the non-grant of future prospects.

Whether the application for additional evidence (I.A. No. 1/2022) to produce the case diary should be allowed?

Whether the offending vehicle was involved in the accident?

Whether the Tribunal erred in deducting 1/3rd for personal expenses instead of 1/2 for a bachelor?

Whether the claimants are entitled to "future prospects" despite the deceased being a daily wager?

The court applied Order XLI Rule 27 of the CPC, noting that additional evidence is an exception and cannot be used to fill lacunae, citing *Union of India v. Ibrahim Uddin*.

Regarding compensation, the court followed *National Insurance Co. Ltd. v. Pranay Sethi*, which mandates a 50% (1/2) deduction for personal expenses of a bachelor.

For future prospects, it applied *Meena Pawaia v. Ashraf Ali*, which established that even for non-salaried or unemployed persons, future prospects must be added as income does not remain static.

Interest rates were guided by *Dharampal v. U.P. SRTC* and *Erudhaya Priya v. State Express Transport Corp. Ltd.*

The Court dismissed the Insurance Company's application for additional evidence, ruling that the existing record (charge sheet and FIR) was sufficient to pronounce judgment.

On the merits, the Court rejected the insurer's plea regarding non-involvement of the vehicle, finding that the charge sheet (Ex.P9) and police reports clearly identified the Bolero Jeep.

Regarding quantum, the Court found the Tribunal's 1/3rd deduction for personal expenses to be legally incorrect; since the deceased was a bachelor, a 1/2 deduction was mandatory per *Pranay Sethi*.

Conversely, the Court agreed with the claimants that the Tribunal failed to award 40% (adjusted to 25% based on age/category) for future prospects.

Following *Meena Pawaia*, the Court held that the "guesswork" income of a daily wager must include a future rise to ensure "just compensation" under Section 168 of the MV Act.

The total compensation was enhanced from ₹9,40,943 to ₹11,98,943.

The Court recalculated the loss of dependency by applying a 1/2 deduction and adding 25% for future prospects.

The interest on the enhanced amount was set at 6% p.a., while the Tribunal's 9% interest on the original award remained undisturbed.

The Insurance Company was directed to deposit the enhanced amount within eight weeks.