Legal Headline Culpability is established through ocular evidence and fringe-inclusive income; subsequent death of a dependent does not reduce compensation.

The Appellants (wife and children of the deceased) challenged a Motor Accident Claims Tribunal (MACT) order dated April 27, 2001

On August 27, 1991, the deceased was riding a motorcycle when he was struck and killed by an MSRTC bus

The MACT found the deceased contributorily negligent, accepting the bus driver’s testimony that the motorcyclist disregarded a signal not to overtake, swerved to avoid cattle, and fell under the bus wheels

The Appellants contended the accident resulted solely from the bus’s excessive speed while overtaking, supported by a passenger/eyewitness account and the site Panchnama

1. Whether the Tribunal erred in holding the deceased contributorily negligent based on the driver's testimony despite contradictory ocular and documentary evidence

2. Whether the income of the deceased was correctly assessed for calculating compensation

3. Whether a handicapped sister qualifies as a "legal representative" entitled to compensation under Section 166 of the Motor Vehicles Act, 1988

The Court applied the principles of Section 166 of the Motor Vehicles Act, 1988, regarding the broad interpretation of "legal representatives"

The Court relied on Baban Shankar Daphal v. State of Maharashtra [2025 INSC 97] and Pruthviraj Jayantibhai Vanol v. Dinesh Dayabhai Vala [(2022) 18 SCC 683] to establish that ocular evidence from a relative is credible if consistent and that "related" witnesses are not automatically "interested"

Regarding compensation and future prospects, the court followed Sarla Verma v. DTC [2009 (6) SCC 121] and National Insurance Co. Ltd. v. Pranay Sethi [(2017) 16 SCC 680]

For dependency of a mother after her death, it applied Kirti v. Oriental Insurance Co. Ltd. [(2021) 2 SCC 166]

The Court found the MACT’s finding of contributory negligence erroneous. It held that the passenger witness's testimony—stating the bus was speeding and struck the motorcycle while overtaking—was more credible than the driver’s uncorroborated account of cattle and oncoming vehicles

The site Panchnama showing right-side damage to the motorcycle and the Post-Mortem report corroborated the ocular evidence

The Court rejected the challenge to the monthly income of ₹3,000, noting that although the base salary was ₹2,294, "fringe benefits" (bonus, medical, etc.) certified in Exh. 25 must be included in the income

Citing N. Jayasree v. Cholamandalam MS General Insurance, the Court ruled that the term "legal representative" must be interpreted liberally; hence, the handicapped sister, having established dependency, was entitled to claim

It enhanced the compensation from ₹1,91,000 to ₹8,80,800, applying a 40% addition for future prospects and a multiplier of 16

The Court directed Respondent No. 1 to pay the balance amount of ₹6,89,800 with 9% interest per annum to the Appellants and the Respondent No. 2 (sister). The appeal was allowed, and the MACT judgment was modified accordingly