Minor's compensation for permanent disability must be calculated using skilled worker minimum wages and a multiplier of 18.

The appellant, a 9-year-old girl, was injured in a motor accident on April 7, 2012, when a motorcycle she was riding was hit by a tractor driven by Respondent No. 2 coming from the wrong side.

She suffered 61% permanent whole-body disability and 55% functional disability.

The Motor Accidents Claims Tribunal (MACT) awarded Rs. 8,14,000/- with 9% interest on March 10, 2017.

The appellant sought enhancement of compensation, challenging the use of a low notional income (Rs. 15,000 p.a.), an incorrect multiplier (10 instead of 18 for a minor), and inadequate non-pecuniary damages.

Whether the notional income of a minor child for calculating loss of future earnings should be based on minimum wages of a skilled worker rather than a fixed static amount.

Whether the appropriate multiplier for a minor child under 15 years of age should be 18 as per recent precedents.

Whether the non-pecuniary damages awarded for pain, suffering, and loss of marriage prospects were adequate.

The Court primarily applied the principles for assessing compensation for minors established in *Kajal v. Jagdish Chand* (2020), which mandates using minimum wages of a skilled worker plus 40% future prospects for disabled children.

It followed *Sarla Verma v. DTC* regarding multipliers, as modified by *Baby Sakshi Greola v. Manzoor Ahmad Simon* (2024) and *Master Ayush v. Reliance General Insurance* (2022), which established that a multiplier of 18 applies to victims under 15 years.

The court also applied *Raj Kumar v. Ajay Kumar* (2011) to categorize pecuniary and non-pecuniary heads.

The court also applied *National Insurance Co. Ltd. v. Pranay Sethi* (2017) for the award of 40% future prospects.

The Court held that the Tribunal erred by applying a static notional income of Rs. 15,000; following *Kajal*, the income must reflect the minimum wages of a skilled worker in Delhi (Rs. 8,528/-) at the time of the accident to account for the child's potential.

Regarding the multiplier, the Court noted that while *Sarla Verma* was silent on ages below 15, subsequent Supreme Court rulings in *Master Ayush* and *Sakshi Greola* have consistently applied a multiplier of 18 for minors.

The Court rejected the Insurance Company’s oral plea for contributory negligence as no cross-appeal was filed.

Finally, it adjusted non-pecuniary damages, noting that as a young girl with significant disability, her marriage prospects and enjoyment of life were severely diminished, necessitating an upward revision.

It held that for minor victims, the multiplier must be 18 and income must be based on skilled minimum wages.

The Court directed Respondent No. 1 to deposit the enhanced amount with 9% interest within four weeks, with specific directions for a lump sum release of Rs. 2,50,000/- and the remainder to be secured in phased Fixed Deposit Receipts to ensure the claimant’s long-term welfare.