Karnataka HC Raises Daughter’s Award For Homemaker Mother’s Death To ₹28.77 Lakh, Valuing Domestic Care At ₹20,000 Monthly Because Her Father Predeceased Her Mother in October 2026

The claimants sought compensation for the death of their mother, B.V. Kamala, in a road accident on 10 April 2021.

The Motor Accident Claims Tribunal awarded ₹21,70,000, including ₹21,00,000 for loss of dependency, and directed the insurer to pay the award with 6% annual interest.

The claimants appealed seeking enhancement.

By the time of the appeal, one claimant had died, and the other claimant was her daughter.

Section 173(1) of the Motor Vehicles Act, 1988, provides for an appeal against an award of the Claims Tribunal.

Under Shishu Pal @ Shish Ram v. Surjeet, 2026 INSC 634, a composite sum of ₹30,000 per month may be added as loss of domestic care when the case involves all three identified components: the homemaker’s contribution to household functioning, loss of maternal support for children, and loss of spousal support; the amount is subject to cumulative 10% revision every three years.

The judgment describes this sum as a stand-in minimum monthly income where the homemaker’s contribution is not expressed in monetary terms.

Under National Insurance Co. Ltd. v. Pranay Sethi, AIR 2017 SC 5157, compensation under conventional heads is subject to periodic escalation; the Court applied a 10% increase in this case.

The Court accepted that the claimants had not proved the deceased’s alleged tailoring income and therefore assessed her contribution as a homemaker.

Because the deceased’s husband had died before the accident, the Court considered the spousal-support component inapplicable and assessed loss of domestic care at ₹20,000 per month rather than ₹30,000.

It added 25% for future prospects, deducted one-third for personal expenses, and applied multiplier 14, arriving at ₹28,00,000 for loss of dependency/domestic care.

The Court also found the accident occurred more than three years after Pranay Sethi and increased consortium, loss of estate, and funeral expenses by 10%.

The Court enhanced total compensation from ₹21,70,000 to ₹28,77,000, entitling the claimant to an additional ₹7,07,000 with interest at 6% per annum from the date of the petition until realization.

The insurer was directed to deposit the enhanced amount within six weeks; 50% was to be released to the claimant and the balance kept in a fixed deposit for three years.