Multiplier selection must strictly adhere to deceased's age documented in evidence, regardless of minor testimonial variations.

On April 19, 2021, Geetaram Chandravanshi died from injuries sustained when a motorcycle (CG-28-K-7467), driven rashly and negligently, dashed into him.

The deceased's widow, children, and mother filed a claim petition seeking ₹39,40,000.

The Tenth Additional Motor Accident Claims Tribunal, Bilaspur, awarded ₹15,75,500 with 9% interest, determining the deceased’s age to be between 46 and 50 years and applying a multiplier of 13.

The appellants challenged this award, contending that the deceased was 45 years old at the time of the accident and thus entitled to a higher multiplier.

Whether the Motor Accident Claims Tribunal erred in its assessment of the deceased's age and the subsequent application of the multiplier for calculating loss of dependency.

The Court primarily applied Section 173 of the Motor Vehicles Act, 1988 regarding appeals against awards.

It heavily relied on the binding precedent established in Sarla Verma & Others v. Delhi Transport Corporation & Others (2009) 6 SCC 121, which standardized the multiplier system based on the age of the deceased, specifically prescribing a multiplier of 14 for the age group of 41 to 45 years.

The High Court observed that while the Tribunal assumed the deceased was aged between 46 and 50, the claimants had consistently pleaded and testified that the deceased was 45 years old.

This assertion was corroborated by the post-mortem report, and the Insurance Company failed to produce any evidence to the contrary.

Consequently, the Court found the Tribunal’s reliance on a multiplier of 13 to be a patent error of law.

By applying the age of 45 years to the Sarla Verma matrix, the Court determined the appropriate multiplier to be 14.

The Court accepted the Tribunal’s previous findings regarding the monthly income (₹9,200), future prospects (25%), and deduction for personal expenses (1/4), but re-calculated the total compensation by substituting the multiplier.

The total compensation was increased from ₹15,75,500 to ₹16,79,000, resulting in an additional award of ₹1,03,500.

The Insurance Company was directed to pay the additional amount within 60 days, while all other terms of the original award remained intact.