Minimum wages must be adopted for notional income assessment in motor accident claims absent documentary proof.

On February 15, 2018, Rameshbhai Babubhai Rathod was a pillion rider on an Activa when a Pick-up Van struck the vehicle from behind due to rash and negligent driving.

The deceased succumbed to serious injuries.

The legal heirs filed a claim petition seeking Rs. 10,00,000/- in compensation.

The Motor Accident Claims Tribunal (Main), Kheda at Nadiad, awarded Rs. 6,04,600/- with 9% interest.

The appellants preferred this appeal on the limited ground of quantum, specifically contesting the notional monthly income of Rs. 6,000/- and the award under conventional heads.

Whether the Tribunal erred in its assessment of the deceased's monthly income and the resulting loss of future dependency.

Whether the compensation awarded under conventional heads (consortium, estate, and funeral expenses) required enhancement as per established precedents.

The court applied the "minimum wages" principle from *Govind Yadav v. National Insurance Co. Ltd.* [2012(1) TAC 1 (SC)] to determine income in the absence of documentary evidence.

For the computation of future dependency, the court followed *Sarla Verma v. Delhi Transport Corporation* [2009 (6) SCC 121] regarding the multiplier (9) and deduction for personal expenses (1/4th).

It further applied *National Insurance Co. Ltd. v. Pranay Sethi* [2017 (16) SCC 680] for conventional heads and *Magma General Insurance Co. Ltd. v. Nanu Ram* [(2018) 18 SCC 130] regarding the entitlement of each dependent to parental/filial/spousal consortium.

The High Court found that since the accident occurred in 2018 and the deceased was an agricultural laborer, the Tribunal's assessment of Rs. 6,000/- was low; it reassessed the income at Rs. 7,950/- based on prevailing minimum wages.

Applying a 10% future prospect addition, a 1/4th deduction for personal expenses, and a multiplier of 9, the court recalculated the loss of future dependency to Rs. 7,08,480/-.

Regarding conventional heads, the court increased "Loss of Estate" and "Funeral Expenses" to Rs. 18,150/- each to account for statutory increments.

Crucially, the court found the Tribunal's lumpsum award of Rs. 40,000/- for consortium improper, reassessing it at Rs. 40,000/- per dependent (totaling Rs. 1,93,600/- for four dependents including 10% enhancement).

The total compensation was enhanced from Rs. 6,04,600/- to Rs. 9,38,380/-.

The respondent (Insurance Company) was directed to deposit the additional amount of Rs. 3,33,780/- with proportionate costs and interest at the rate awarded by the Tribunal within four weeks.

The court further directed the deduction of deficit court fees on the enhanced amount before disbursement to the claimants via RTGS/NEFT.