Motor accident claimants are entitled to just compensation based on properly assessed income and conventional damages.

The appellants, original claimants and legal heirs of deceased Natvarbhai Arjanbhai Parmar, challenged the judgment and award dated 12 August 2025 passed by the Motor Accident Claims Tribunal, Nadiad, in Motor Accident Claim Petition No. 597 of 2024 under Section 173 of the Motor Vehicles Act, 1988.

They contended that the Tribunal had awarded inadequate compensation by incorrectly assessing the deceased’s income, future prospects, dependency, and conventional heads of damages.

The Insurance Company defended the award as just and proper.

Whether the Tribunal had correctly assessed the deceased’s income and the resultant loss of dependency.

Whether the claimants were entitled to enhanced compensation under the heads of future dependency, loss of estate, funeral expenses, and loss of consortium.

Whether the claimants were entitled to interest on the enhanced compensation and consequential directions for its deposit and disbursement.

The Court applied Section 173 of the Motor Vehicles Act, 1988, governing appeals against awards of the Motor Accident Claims Tribunal.

It reiterated that the Motor Vehicles Act is beneficial legislation and that compensation must be “just,” fair, reasonable, equitable, and based on a realistic and liberal assessment rather than a narrow or niggardly approach.

For conventional damages, it relied on National Insurance Co. Ltd. v. Pranay Sethi, (2017) 16 SCC 680, awarding Rs.18,150 each towards loss of estate and funeral expenses, and on United India Insurance Co. Ltd. v. Satinder Kaur @ Satwinder Kaur, (2021) 11 SCC 780, awarding Rs.48,400 to each of the four dependants towards loss of consortium.

The High Court found that the Tribunal had not properly considered the deceased’s monthly income and therefore reassessed the compensation.

Applying the principle of just compensation and the cited Supreme Court precedents, it determined future dependency loss at Rs.26,68,032.

It further awarded Rs.18,150 each for loss of estate and funeral expenses and Rs.48,400 to each of the four dependants for loss of consortium, totalling Rs.2,29,900 under those heads.

The total compensation was consequently calculated at Rs.28,97,932. After deducting the Tribunal’s award of Rs.18,21,800, the Court found that an additional Rs.10,76,132 was payable.

The Insurance Company was directed to deposit the enhanced amount within six weeks of receiving the order.

The Tribunal was directed to disburse the entire awarded amount, including accrued interest, to the claimants by account-payee cheque, NEFT, or RTGS after due verification, subject to deduction of court fees, if applicable.

The remaining directions of the Tribunal were left undisturbed.