Notional income for motor accident claims must align with the prevailing minimum wage matrix for unskilled labor.

On May 28, 2019, Rajkumar Sai died due to injuries sustained in a motor vehicle accident involving a motorcycle (bearing registration No. CG-14-MH-2827) driven in a rash and negligent manner.

The claimants (parents of the deceased) filed a claim under Section 173 of the Motor Vehicles Act, 1988, seeking compensation of Rs. 30,25,000/-, stating the deceased was an 18-year-old agricultural laborer earning Rs. 10,000/- per month.

The Additional Motor Accident Claims Tribunal, Jashpur, awarded Rs. 11,68,400/- with 6% interest, assessing a notional income of Rs. 7,000/- per month.

The appellants challenged this award, seeking an enhancement based on the minimum wage matrix.

1. Whether the learned Tribunal erred in assessing the notional income of the deceased at Rs. 7,000/- per month instead of following the prevailing minimum wage standards for unskilled laborers in Chhattisgarh.

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

It relied on the principle of "just compensation" and the standardized minimum wage matrix applicable in the State of Chhattisgarh for the relevant period (May 2019) to determine notional income in the absence of documentary evidence.

Furthermore, it applied the standards for future prospects (40% for the age group), deduction for personal expenses (1/2 for a bachelor), and conventional heads (Loss of Estate, Funeral Expenses, and Consortium) as established by prevailing judicial precedents.

The Court observed that while the claimants could not provide documentary proof of the deceased's specific monthly income, the Tribunal’s assessment of Rs. 7,000/- was incorrect as it fell below the statutory minimums.

The Court noted that the minimum wage for an unskilled laborer in Chhattisgarh in May 2019 was actually Rs. 8,400/- per month.

By substituting this figure into the computation, the Court recalculated the annual income to Rs. 1,00,800/-.

Applying a 50% deduction for personal expenses (leaving Rs. 50,400/-), a multiplier of 18 (for the age of 18 years), and adding 40% for future prospects (Rs. 3,62,880/-), the Court determined the total dependency loss.

The Court maintained the Tribunal's awards for conventional heads, including Rs. 80,000/- for consortium and Rs. 30,000/- for funeral and estate expenses, as they were deemed just.

The total compensation was increased from Rs. 11,68,400/- to Rs. 13,80,080/-, granting an additional amount of Rs. 2,11,680/-.

The Insurance Company (Respondent No. 3) was directed to pay the additional amount within 60 days, while all other terms and interest rates of the original award remained intact.