Headline: Earning status of surviving husband does not preclude compensation for loss of dependency of deceased wife.

The deceased, Ms. Nidhi Jain (33), was a postgraduate and a "Salaried Director" with a private company

On January 26, 2022, she died in an accident on NH-58 involving a truck insured by the Appellant

The Motor Accident Claims Tribunal (MACT) awarded Rs. 57,64,476/- to the Respondent No. 1 (husband), calculating "loss of dependency" based on the deceased's income after a 50% deduction for personal expenses

The Insurance Company appealed, contending that since the husband was an earning member, he was not "financially dependent" on his wife and was only entitled to compensation under the head of "loss to estate"

1. Whether an earning husband is entitled to compensation under the head of "loss of dependency" for the death of his earning wife

2. Whether the principles of "loss to estate" established in Keith Rowe v. Prashant Sagar apply to dependent family members like a spouse

Section 166(1)(c) of the Motor Vehicles Act, 1988, which allows any legal representative to claim compensation

National Insurance Co. Ltd. v. Pranay Sethi and Sarla Verma v. DTC for the standardized calculation of dependency using income, future prospects, and multipliers

Arun Kumar Agarwal v. National Insurance Company Ltd., which recognized that a wife’s contribution (pecuniary or via services) is invaluable and must be monetized

The "loss to estate" restrictive formula from A. Manavalagan v. A. Krishnamurthy and Keith Rowe v. Prashant Sagar applies only to non-dependent legal heirs (like siblings) and not to the "head unit" of the family (spouse, parents, children)

The Court rejected the Appellant’s "patriarchal" assumption that an earning husband cannot be dependent on his wife.

The Court reasoned that "dependency" in motor accident law is not limited to literal financial destitution but includes the loss of contribution to the "joint household corpus" and the loss of domestic services.

In modern households with joint incomes, the death of one spouse causes a clear pecuniary loss to the survivor's lifestyle and savings.

The Court distinguished Keith Rowe, noting that a subsequent clarification in Indrawati v. Ranbir Singh specifically precluded the "loss to estate" approach for spouses and parents, even if they are earning.

The Court found that since the deceased contributed to home loans and rent, the husband’s dependency was factually established and unrebutted during the trial.

On Issue 2, it held that the "loss to estate" principle is globally distinct and reserved for non-dependent claimants.

The Court dismissed the appeal, upheld the MACT’s award of Rs. 57,54,476/- with 9% interest, and ordered the disbursement of the balance amount to the husband.