Income-tax returns establish the deceased’s monthly income for computing motor accident compensation.

The accident and the insurer’s liability to pay compensation were undisputed. The Motor Accident Claims Tribunal assessed the deceased’s monthly income at ₹6,000 and awarded total compensation of ₹10,85,800.

The claimants appealed, contending that income-tax returns produced at Exhibits 38 and 39 established an average monthly income of ₹8,000, and sought enhancement of compensation.

The insurer did not dispute the filing or relevance of the income-tax returns.

Whether the deceased’s monthly income should be reassessed from ₹6,000 to ₹8,000 on the basis of the income-tax returns at Exhibits 38 and 39.

Whether the claimants were entitled to enhanced compensation by applying future prospects and revised conventional heads, including loss of consortium, loss of estate, and funeral expenses.

Whether the Tribunal’s award of interest at 9% per annum required interference.

The Court applied the principles governing computation of compensation under the Motor Vehicles Act, including determination of actual income from reliable documentary evidence, addition of future prospects, deduction for the deceased’s personal expenses, and application of the appropriate multiplier.

It relied on National Insurance Co. Ltd. v. Pranay Sethi for future prospects and conventional compensation, read with Reena v. Managing Director, Karnataka State Road Transport Corporation, reported at 2026 (0) AIJEL-SC 77486, concerning loss of consortium and other non-pecuniary heads.

The Court also affirmed that the rate of interest awarded by the Tribunal should not be disturbed where it is just and proper.

The income-tax returns demonstrated that the deceased’s average monthly income was ₹8,000, and the insurer did not dispute their filing; accordingly, the Court substituted ₹8,000 for the Tribunal’s assessment of ₹6,000.

Applying a 40% increase for future prospects, the monthly income became ₹11,200. After deducting one-fourth towards personal expenses, the monthly contribution to the dependants was assessed at ₹8,400, resulting in an annual loss of ₹1,00,800.

Applying a multiplier of 17, the loss of future income was calculated at ₹17,13,600.

The Court additionally awarded ₹52,000 each to four claimants towards loss of consortium, totalling ₹2,08,000, along with ₹19,500 each for loss of estate and funeral expenses.

The resulting total compensation was ₹19,60,600, producing an enhancement of ₹8,74,800 over the Tribunal’s award.

The existing interest rate of 9% per annum was considered just and was therefore maintained.

The total compensation was enhanced from ₹10,85,800 to ₹19,60,600, with the additional compensation fixed at ₹8,74,800.

The award continued to carry interest at 9% per annum.

The respondent-insurer was directed to deposit the enhanced amount with interest within eight weeks from receipt of the judgment, and the record and proceedings were ordered to be returned to the Tribunal.