Motor accident compensation must include future prospects and consortium for each eligible claimant under Supreme Court precedent.

On 22 December 2012, an accident occurred between a tanker and a truck, resulting in the death of the tanker’s driver. His widow and three children filed a motor accident compensation claim petition.

The Motor Accident Claims Tribunal assessed the deceased’s monthly income at ₹7,000, his age at approximately 50 years and six months, and awarded ₹11,24,700, comprising loss of future income, loss of love and affection/loss of estate, and funeral expenses.

The insurers accepted the Tribunal’s award; the claimants alone appealed seeking enhancement.

The High Court reconsidered the deceased’s income, future prospects, deductions, conventional heads of compensation, and rate of interest.

Whether the deceased’s monthly income should be enhanced from ₹7,000 to ₹10,000, having regard to his occupation as a tanker driver?

Whether the claimants were entitled to an addition towards future prospects and, after deducting the deceased’s personal expenses, what amount was payable towards loss of dependency?

Whether the compensation under the conventional heads, including loss of consortium, loss of estate, and funeral expenses, required enhancement?

Whether the rate of interest awarded by the Tribunal should be enhanced from 7.5% to 9% per annum?

The Court applied the principles governing computation of compensation under the Motor Vehicles Act, particularly the structured assessment of loss of dependency based on established income, future prospects, personal-expense deductions, and the applicable multiplier.

Relying on National Insurance Co. Ltd. v. Pranay Sethi, AIR 2017 SC 5157, the Court held that a deceased aged between 50 and 60 years was entitled to a 10% addition towards future prospects and that standardized amounts should be awarded under conventional heads.

It further relied on Reena v. Managing Director, Karnataka State Road Transport Corporation, 2026 (0) AIJEL-SC 77486, as applied with Pranay Sethi, for awarding ₹52,000 per claimant towards loss of consortium and ₹19,500 each towards loss of estate and funeral expenses.

The Court considered the deceased’s occupation as a tanker driver and found that tanker drivers generally work longer hours and earn more than ordinary drivers; it therefore fixed his monthly income at ₹10,000 instead of ₹7,000.

Since the deceased was aged 50 years and six months, the Court added 10% towards future prospects, resulting in a monthly income of ₹11,000.

As there were four dependants, one-fourth was deducted towards personal expenses, leaving a monthly dependency contribution of ₹8,250. Applying the multiplier of 13, the loss of future income was calculated at ₹12,87,000.

The Court additionally awarded ₹2,08,000 towards loss of consortium, calculated at ₹52,000 for each of the four claimants, and ₹19,500 each towards loss of estate and funeral expenses.

The total compensation was consequently recalculated at ₹15,34,000, and interest was enhanced to 9% per annum.

The High Court enhanced the total compensation from ₹11,24,700 to ₹15,34,000 and awarded the claimants an additional amount of ₹4,09,300, carrying interest at 9% per annum from the date of filing of the claim petition until realization.

The enhanced amount was directed to be deposited within ten weeks from receipt of the order and disbursed to the claimants by NEFT/RTGS after proper verification.