Motor accident compensation must reflect notified minimum wages and applicable conventional heads.

Suresh Prashad Soni, aged approximately 49 years, died in a motor vehicle accident on 18 November 2024.

His legal representatives filed a claim petition before the Principal Motor Accident Claims Tribunal, Ambikapur, Surguja, which awarded total compensation of ₹17,11,195 by award dated 8 December 2025 in Claim Case No. 44/2025.

The claimants preferred an appeal under Section 173 of the Motor Vehicles Act, 1988, seeking enhancement on the grounds that the deceased’s income and the amounts awarded under conventional heads had been assessed inadequately.

The insurer opposed the appeal and supported the Tribunal’s award.

Whether the Tribunal erred in assessing the deceased’s monthly income at ₹10,000 instead of ₹10,428, as allegedly prescribed under the applicable Chhattisgarh minimum-wages notification.

Whether the compensation awarded under conventional heads was inadequate and required enhancement in accordance with the applicable principles governing motor accident compensation.

Whether the claimants were entitled to enhancement of the total compensation awarded by the Tribunal.

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

For computation of loss of dependency, it relied on Sarla Verma v. Delhi Transport Corporation, (2009) 6 SCC 121, including the principles concerning deduction for personal expenses and the appropriate multiplier.

It applied National Insurance Co. Ltd. v. Pranay Sethi, (2017) 16 SCC 680, regarding addition of future prospects and conventional heads of compensation.

It also relied on Magma General Insurance Co. Ltd. v. Nanu Ram @ Chuhru Ram, (2018) 18 SCC 1305, concerning compensation under conventional heads, including consortium-related compensation.

The Court accepted the applicable minimum-wage income of ₹10,428 per month and recalculated compensation by adding 25% for future prospects, deducting one-fourth towards personal expenses, applying a multiplier of 13, and awarding the appropriate amounts under conventional heads.

The Court found that the Tribunal had assessed the deceased’s monthly income at ₹10,000, whereas the applicable Chhattisgarh minimum-wage notification supported an income of ₹10,428 per month.

Applying the established principles in Pranay Sethi, Sarla Verma, and Magma General Insurance, the Court calculated the annual income at ₹1,25,136, added 25% towards future prospects to arrive at ₹1,56,420, deducted one-fourth towards personal expenses, and applied the multiplier of 13, resulting in ₹15,25,095 towards loss of dependency.

The Court further enhanced the amount under conventional heads from ₹2,04,000 to ₹2,76,000, while retaining medical expenses of ₹44,695.

The recalculated total compensation was therefore ₹18,45,790, as against the Tribunal’s award of ₹17,11,195.

The compensation was enhanced from ₹17,11,195 to ₹18,45,790, resulting in an additional amount of ₹1,34,595 payable to the appellants.

The enhanced amount was directed to carry interest at 6% per annum from the date of filing of the claim application until realization.

Appellant No. 2, Prince Kumar Soni, was directed to receive ₹48,000 out of the total compensation.

All other conditions of the Tribunal’s award were left undisturbed.

The Registry was directed to communicate the enhanced amount to the claimants in Hindi Devanagari, with assistance from paralegal workers where necessary.