Minimum wages are determined by the deceased’s place of employment, not recorded permanent residence.

Ramesh died in a motor-vehicle accident on 26 January 2021 near Jhimar Pur Village, Delhi.

His legal representatives filed a claim petition, and the Motor Accident Claims Tribunal, North-West District, Delhi, awarded compensation of ₹23,78,774 with interest at 9% per annum by award dated 1 April 2026.

The Tribunal assessed the deceased’s benchmark income on the basis of Delhi minimum wages, relying substantially on the testimony of his father, Poma Ram/PW1, who stated that Ramesh was residing and working as an agricultural labourer on batai basis at Village Khair Pur and Punjab Khore, Delhi.

The Insurance Company challenged the award, contending that the deceased was a resident of Rajasthan and that his income should have been assessed using Rajasthan minimum wages, since his Aadhaar card, driving licence, ration card and unmarried certificate were issued or recorded in Rajasthan.

Whether the deceased’s benchmark income should be assessed according to the minimum wages applicable in Delhi or Rajasthan, considering that his identity and residence documents reflected Rajasthan but the oral evidence placed his employment and residence in Delhi.

Whether the absence of documentary proof of employment or residence in Delhi was sufficient to displace the consistent and substantially unrebutted testimony of the deceased’s father.

Whether the Tribunal’s award of ₹23,78,774 with interest at 9% per annum warranted appellate interference.

Claims under the Motor Vehicles Act, 1988, are decided on the basis of just and reasonable compensation, and strict rules of evidence applicable to criminal trials do not govern proceedings before the Motor Accident Claims Tribunal; the applicable standard is preponderance of probabilities rather than proof beyond reasonable doubt.

Under the guideposts in Savita v. National Insurance Co. Ltd., in the absence of documentary proof, the Court may determine the place of employment from the overall facts and circumstances, including oral testimony of immediate family members and documents such as driving licences and voter identity cards; income may be assessed using an appropriate minimum-wage category without mechanically applying the lowest tier.

The Court also relied on United India Insurance Co. Ltd. v. Badal, New India Assurance Co. Ltd. v. Pratima Kumari and New India Assurance Co. Ltd. v. Bindu Devi for the principle that workers residing outside Delhi may nevertheless be entitled to Delhi minimum wages where evidence establishes employment or work in Delhi.

The principles in Prabhavathi v. Bangalore Metropolitan Transport Corpn. and Sebati Nath v. Shriram General Insurance Co. Ltd. reaffirmed the non-application of strict criminal-trial evidentiary standards in motor accident compensation proceedings.

The High Court acknowledged that all formal identity and residence documents reflected Rajasthan, but held that those documents were not determinative of the deceased’s actual place of work at the time of the accident.

Poma Ram’s testimony specifically identified the landowners, the locations of the agricultural land and the deceased’s residence in Delhi, rather than merely making a general assertion of Delhi employment.

The testimony was not substantially shaken in cross-examination.

Further, the accident occurred while the deceased was travelling from the Punjab Khore area towards Khair Pur after visiting Bawana, which was consistent with the asserted Delhi residence and work pattern.

Applying the preponderance-of-probabilities standard and the beneficial nature of motor-accident legislation, the Court concluded that the evidence sufficiently established that the deceased was working in Delhi. Accordingly, Delhi minimum wages were correctly applied.

The decision in Oriental Insurance Co. Ltd. v. Kirti was distinguished because it involved a specific concession by the claimants to apply Haryana minimum wages and therefore did not govern the present facts.

The consistent and substantially unrebutted testimony regarding his Delhi employment and residence, coupled with the circumstances of the accident, was sufficient on a balance of probabilities.

The appeal filed by the Insurance Company was dismissed, the Tribunal’s award of ₹23,78,774 with interest at 9% per annum was left undisturbed, pending applications were rendered infructuous, and the statutory amount was directed to be refunded to the Insurance Company.