Karnataka High Court applies ₹30,000 monthly value for homemaker’s domestic care, raises family’s compensation to ₹61.8 lakh

The appellants, the deceased’s husband and minor daughter, sought enhancement of compensation arising from her death in a road traffic accident on 19 June 2023.

The Motor Accident Claims Tribunal awarded ₹33,44,528, including ₹32,25,528 for loss of dependency, and directed the insurer to pay interest at 6% per annum.

The claimants appealed, contending that the deceased was a homemaker and that the loss of domestic care should be assessed at ₹30,000 per month; they also stated that she did coolie work, but produced no evidence of that income.

1. Whether, in assessing compensation for the death of a homemaker, the deceased’s contribution to domestic care should be valued at ₹30,000 per month.

2. Whether the claimants were entitled to enhancement under the heads of dependency/care and conventional compensation.

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

In Shishu Pal @ Shish Ram and Others v. Sujeet and Others, 2026 INSC 634, the Supreme Court held that, where a homemaker has no provable monetary income, ₹30,000 per month may be taken as a stand-in for loss of domestic care where the relevant forms of domestic and family support are lost; where the homemaker was also part of the workforce, proven income is additional to that amount.

Under National Insurance Co. Ltd. v. Pranay Sethi and Others, (2017) 16 SCC 680, the Court applied a 20% enhancement to consortium, loss of estate, and funeral expenses.

The deceased was aged 25, and her husband and minor daughter had lost her care and support.

Applying Shishu Pal, the Court assessed loss of domestic care at ₹30,000 per month.

Although the claimants stated that the deceased also worked as a coolie, they produced no proof of that income, so no additional amount was included.

The Court added 40% for future prospects, applied a multiplier of 18, and deducted one-third for personal expenses, calculating loss of care/dependency at ₹60,48,000.

It then applied the Pranay Sethi enhancement to the conventional heads and assessed total compensation at ₹61,80,000.

The Court enhanced the award from ₹33,44,528 to ₹61,80,000, granting an additional ₹28,35,472 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; the claimants were to receive equal shares, with the minor’s share placed in fixed deposit until majority and 50% of the first appellant’s share released, with the balance held in fixed deposit for three years.