No enhancement is warranted where the Tribunal correctly assessed income and future prospects.

The claimants, the widow and children of Gauthar Singh, along with his parents, sought enhancement of compensation awarded for his death in a road accident on 25 April 2017.

The Motor Accident Claims Tribunal awarded ₹19,77,880.

In their appeal under Section 173 of the Motor Vehicles Act, 1988, the claimants challenged the Tribunal’s assessment of the deceased’s monthly income and its addition of 25% for future prospects, contending that income should have been calculated on 30 days’ work and future prospects at 40%.

The insurer opposed enhancement.

1. Whether the Tribunal erred in assessing the deceased’s monthly income at ₹8,866, including by calculating wages on 26 rather than 30 working days.

2. Whether the Tribunal erred in adding 25%, rather than 40%, towards future prospects for a deceased aged about 40 years.

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 Company Ltd. v. Pranay Sethi, (2017) 16 SCC 680, and Sarla Verma & Ors. v. Delhi Transport Corporation & Ors., (2009) 6 SCC 121, as authorities governing the assessment of future prospects and compensation.

The Court treated the Tribunal’s addition of 25% for future prospects in respect of a deceased aged about 40 years as consistent with those decisions.

The Court rejected the challenge to the income assessment, noting that the applicable Chhattisgarh minimum-wage notification indicated monthly income of ₹7,930, whereas the Tribunal had assessed it at the higher figure of ₹8,866; the Tribunal’s assessment was therefore just and proper.

It also held that, given the deceased’s age of about 40 years, the Tribunal’s addition of 25% for future prospects accorded with Pranay Sethi and Sarla Verma.

The Court accordingly found no basis to enhance the award.

No enhancement was granted.