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

The claimants, the widow, minor children and parents of Roop Singh, appealed under Section 173 of the Motor Vehicles Act, 1988, seeking enhancement of compensation for his death in a road accident on 26 January 2024.

The Motor Accident Claims Tribunal had assessed compensation at ₹17,40,760, based on a monthly income of ₹7,800 and ₹70,000 under conventional heads.

The claimants contended that both figures were inadequate

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

In assessing compensation, the Court relied on National Insurance Co. Ltd. v. Pranay Sethi, which addresses future prospects and conventional heads; Sarla Verma & Ors. v. Delhi Transport Corporation & Anr., concerning the multiplier and deduction for personal expenses; and Magma General Insurance Co. Ltd. v. Nanu Ram @ Chuhru Ram & Ors., concerning compensation under conventional heads.

The Court applied a 40% addition for future prospects, a one-fourth deduction for personal expenses, a multiplier of 17, and ₹2,76,000 under conventional heads.

The Court found that the Tribunal’s monthly income assessment of ₹7,800 was lower than the ₹10,100 monthly minimum wage applicable under the Chhattisgarh Minimum Wages Notification.

Applying the stated 40% future-prospects addition, one-fourth deduction and multiplier of 17 to the revised income, the Court calculated loss of dependency at ₹21,63,420.

It also increased compensation under conventional heads from ₹70,000 to ₹2,76,000, producing a total award of ₹24,39,420.

The additional amount carries interest at 6% per annum from the date of filing the claim application until realization; the remaining terms of the Tribunal’s award remain unchanged.

The Registry was directed to communicate the enhanced amount to the claimants in Hindi, with paralegal assistance if required.