Minimum wage notifications govern income assessment for skilled deceased persons in motor accident compensation claims.

The appellants, parents of the deceased Vishwajeet Kanwar, filed an appeal under Section 173 of the Motor Vehicles Act, 1988, seeking an enhancement of the compensation awarded by the 8th Additional Motor Accident Claims Tribunal (MACT), Bilaspur.

The deceased was a 20-year-old ITI student and electrician who died in a motor accident.

The Tribunal, vide award dated 29-11-2019, granted a total compensation of ₹13,59,392/-.

The appellants contended that the Tribunal incorrectly assessed the deceased's monthly income at ₹8,660/- despite his status as a skilled laborer.

1. Whether the monthly income of the deceased was correctly assessed by the Tribunal in accordance with the Minimum Wages Act and the deceased's professional qualifications.

2. Whether the claimants are entitled to enhanced compensation under conventional heads and future prospects.

The Court primarily applied Section 173 of the Motor Vehicles Act, 1988.

It relied on the Chhattisgarh Minimum Wages Notification issued by the Office of the Labour Commissioner to determine the income of skilled workers.

For the computation of compensation, the Court followed the principles laid down in National Insurance Company Ltd. v. Pranay Sethi, which standardized future prospects and conventional heads.

Sarla Verma & Ors. v. Delhi Transport Corporation & Ors., regarding the multiplier and personal expense deductions.

Magma General Insurance Co. Ltd. v. Nanu Ram @ Chuhru Ram & Ors., regarding the entitlement of each parent to parental consortium.

The Court noted that the deceased was an ITI student and an electrician, qualifying him as a skilled laborer.

Consequently, it revised the monthly income from ₹8,660/- to ₹9,830/- based on the prevailing Minimum Wages Notification.

Following the Sarla Verma guidelines, the Court applied a multiplier of 18 (for the age group of 20 years) and deducted 1/2 of the income toward personal and living expenses as the deceased was unmarried.

In line with Pranay Sethi, the Court added 40% for future prospects.

Under conventional heads, the Court enhanced 'Loss of Estate' and 'Funeral Expenses' to ₹18,750/- each (reflecting a 25% increase) and awarded ₹48,400/- each to the mother and father for 'Loss of Parental Consortium' per the Magma General ruling.

The appellants were held entitled to an additional amount of ₹2,61,204/-.

The Court directed the Insurance Company to deposit the enhanced amount within 45 days, carrying an interest rate of 6% per annum from the date of the claim filing (07-03-2019) until realization.

All other conditions of the original award remained intact.