Karnataka HC Raises Farmer’s Family’s Compensation To ₹25 Lakh After Bullock-Cart Crash, Citing His Work On 11 Acres of Land

The deceased, an agricultural landowner, died when a mini goods vehicle struck his bullock cart while he was travelling to carry out agricultural work.

The Tribunal awarded his dependants ₹16,36,630, including ₹14,66,630 for loss of dependency and ₹1,00,000 for damage to the cart and injuries to the bullocks.

The insurer appealed seeking a reduction, while the claimants appealed seeking enhancement. The accident and the insurer’s liability were not in dispute.

Under Section 173(1) of the Motor Vehicles Act, 1988, an aggrieved party may appeal an award of the Motor Accidents Claims Tribunal.

In assessing loss arising from the death of a person whose livelihood involves agriculture, the court may account for the loss of the deceased’s supervisory contribution to the land, even where the agricultural land remains with the family; State of Haryana v. Jasbir Kaur and Surekha v. Cargo Carriers India were cited on this principle and on estimating supervisory charges.

The court also referred to Shailaja v. Pavan Udupadi concerning agricultural supervision charges.

Conventional heads were assessed with reference to National Insurance Co. Ltd. v. Pranay Sethi. The court relied on Ramla v. National Insurance Co. Ltd. in considering compensation for the cart and bullock losses, and on Puttamma v. K.L. Narayana Reddy and United India Insurance Co. v. Malyadari in determining interest.

The RTC showed that the deceased owned 11 acres and 5 guntas of dry land, and the contemporaneous complaint and the widow’s evidence supported the finding that he personally undertook agricultural work and that the family depended on its income.

The court considered both the claimed annual income of ₹5,00,000 and the supervisory-charge approach in the cited authorities, and concluded that a monthly income of ₹25,000 was appropriate.

After deducting one-third for personal expenses, it calculated annual dependency at ₹2,00,000 and applied multiplier 11, producing ₹22,00,000 for loss of dependency.

It found no reason to disturb the ₹1,00,000 global award for the cart and bullock losses, given the likely disruption to agricultural operations and replacement costs. It modified the conventional heads and increased interest to 9% per annum.

The award was modified to ₹25,00,000, with interest at 9% per annum from the date of the petition until realization.

The insurer was directed to deposit the compensation and accrued interest before the Tribunal within eight weeks of receiving a certified copy of the judgment.