Minimum wages of the home state apply for compensation absent proof of employment in Delhi.

On September 20, 2011, Smt. Sunita was traveling in a TSR towards Anand Vihar when a negligently driven tractor (bearing registration no. UP 81 AJ 8506) hit the vehicle, causing it to overturn

Smt. Sunita succumbed to fatal injuries

The Motor Accidents Claims Tribunal (MACT), Karkardooma Courts, awarded the appellants compensation of Rs. 12,79,656/- with 9% interest via an award dated August 25, 2014

The Appellants approached the High Court seeking enhancement of compensation, contending that the MACT erred by applying minimum wages of Madhya Pradesh instead of Delhi and by miscalculating the multiplier based on the deceased's age

Whether the minimum wages of Delhi should be applied for calculating loss of dependency in the absence of documentary evidence proving the deceased’s employment in Delhi.

Whether the MACT applied the correct multiplier based on the age of the deceased at the time of the accident.

The court applied the principle of "just and reasonable compensation" under the Motor Vehicles Act, 1988

It relied on the precedent that minimum wages should be assessed based on the State where the deceased was actually employed

Regarding the calculation of age and multipliers, it followed the established practice of determining age through corroborated documentary evidence, such as Ration Cards and Election ID cards, to apply the corresponding multiplier as per the age brackets defined in Sarla Verma v. DTC

Regarding the first issue, the Court noted that while the accident occurred in Delhi, the Appellants' own documents (Ration Card and Election ID) were issued in Rajnagar, Madhya Pradesh

The Court distinguished *Hitesh Nagjibhai Patel v. Bababhai Nagjibhai Rabari* (2025 INSC 1070), noting that the principle of "place of cause of action" for wages applies to minors, but for adults, there must be "cogent evidence" of employment in the specific state

Since the oral testimony of PW1 was silent on the place of employment and the supporting affidavit only stated "at present Delhi," the Court found no reason to deviate from the Madhya Pradesh minimum wage standard

Regarding the second issue, the Court found that although the MACT's presumption of age lacked a clear initial basis, the 2006 Ration Card showed the deceased was two years younger than her husband

Since the husband was 36 at the time of the accident, the deceased was 34, placing her squarely within the 31–35 age group, which correctly warrants a multiplier of 16

It held that the MACT was correct in applying the minimum wages of Madhya Pradesh as the deceased's residence was proven there and her employment in Delhi was not established

It further held that the multiplier of 16 remained appropriate for a 34-year-old deceased

The appeal was dismissed, and all pending applications were rendered infructuous