Motor Accident Compensation: Enhancement of Multiplier, Future Prospects, and Consortium Awarded per Pranay Sethi Principles.

The deceased sustained fatal crush injuries on February 15, 2010, when a bus driver negligently put the vehicle in motion while the deceased was boarding at a bus stop in RK Puram

An FIR was registered, and the Motor Accident Claims Tribunal (MACT) subsequently awarded compensation of Rs. 23,35,976/- with 7.5% interest via an award dated November 27, 2012

The Appellants filed the present appeal seeking enhancement of the compensation, challenging the income assessment, the multiplier used, and the omission of future prospects and non-pecuniary heads

1. Whether the income of the deceased should be calculated at Rs. 37,000/- instead of Rs. 33,750/- based on conflicting salary records

2. Whether the compensation must be realigned with established legal principles regarding multipliers, future prospects, and general damages

The Court applied the computation standards for motor accident claims established in National Insurance Co. Ltd. v. Pranay Sethi (2017), which mandates specific percentages for future prospects and standardized amounts for loss of consortium and funeral expenses

It also applied the evidentiary rule that oral testimony in cross-examination (confirming a lower salary figure) may outweigh subsequent salary certificates

followed United India Insurance Co. Ltd. v. Satinder Kaur (2021), which directs that "loss of love and affection" is not a separate head of compensation when "loss of consortium" is granted

Regarding income, the Court upheld the Tribunal's assessment of Rs. 33,750/- per month, noting that the employer’s witness (PW2) admitted this figure during cross-examination as the total salary including benefits, and rejected a later salary certificate as inapplicable to the date of the accident

Following Pranay Sethi, the Court adjusted the multiplier from 9 to 11 because the deceased was 55 years old

It further added 10% for future prospects, which the Tribunal had omitted

While deleting the Rs. 25,000/- previously awarded for "love and affection" per Satinder Kaur, the Court significantly increased "loss of consortium" to Rs. 1,20,000/- (Rs. 40,000 per dependent) and added Rs. 15,000/- for "loss of estate" to meet constitutional bench standards

The Court ordered a total enhancement of Rs. 8,87,391/- along with 7.5% interest per annum. The Insurance Company was directed to deposit the enhanced amount within six weeks, to be released to the claimants as a lumpsum payment in accordance with the Tribunal’s original apportionment