Minor siblings were not treated as dependents, warranting a 50% personal-expense deduction.

The claimants, the parents and three minor siblings of the deceased, appealed under Section 173 of the Motor Vehicles Act, 1988, seeking enhancement of the compensation awarded for his death in a road accident.

The Tribunal awarded ₹15,89,632, including ₹2,50,000 under conventional heads.

The claimants challenged the deduction of one-half of the deceased’s income for personal and living expenses, arguing that his siblings were also dependants, and sought enhancement under conventional heads.

Whether the deceased’s minor siblings could be treated as financial dependants so as to justify a deduction of less than one-half of his income for personal and living expenses.

Whether the amounts awarded for loss of estate and funeral expenses required enhancement under the principles in National Insurance Company Ltd. v. Pranay Sethi.

Section 173 of the Motor Vehicles Act, 1988 provides for an appeal against an award of the Claims Tribunal.

Under the principles applied in National Insurance Company Ltd. v. Pranay Sethi, conventional awards for loss of estate and funeral expenses are subject to periodic enhancement; the Court applied a 10% increase to the Tribunal’s awards of ₹15,000 under each head.

The Court also applied the rule that the deduction for an unmarried deceased’s personal and living expenses depends on the relevant dependency circumstances; here, it found no basis to treat the siblings as financially dependent on the deceased.

The Court found that the claimants’ parents were aged about 38 and 40, while the deceased’s siblings were minors.

In the circumstances, it was not reasonable to regard the siblings as financially dependent on the deceased, and the Court therefore upheld the one-half deduction made by the Tribunal.

The deceased’s monthly income of ₹8,860 and the consortium award of ₹44,000 for each of the five claimants were not disputed.

Applying Pranay Sethi, the Court increased loss of estate and funeral expenses from ₹15,000 to ₹16,500 each, bringing the total under conventional heads to ₹2,53,000.

The claimants were awarded an additional ₹3,000, with interest at 6% per annum from the date of filing the claim petition until realization.

The award was modified to that extent, with its remaining terms left intact.