Notional income for motor accident compensation must align with Minimum Wages Act notifications at the relevant time.

The Appellants (daughter and grandsons of the deceased) filed an appeal under Section 173 of the Motor Vehicles Act, 1988, seeking enhancement of compensation awarded by the Additional Motor Accident Claims Tribunal, Katghora

The Tribunal had awarded ₹3,14,000/- with 7% interest for the death of Sushila Bai Shrivas (aged 55) in a motor accident

The Appellants contended that the Tribunal erred by assessing the deceased's monthly income at a nominal ₹3,000/- instead of following the Minimum Wages Notification

1. Whether the Claims Tribunal erred in its assessment of the deceased's notional monthly income and the subsequent calculation of compensation

The Court applied the statutory framework of the Motor Vehicles Act, 1988, and the Chhattisgarh Minimum Wages Notification issued by the Office of Labour Commissioner

It relied on the landmark precedents of National Insurance Company Ltd. v. Pranay Sethi (2017) regarding future prospects and conventional heads

Sarla Verma & Ors. v. Delhi Transport Corporation & Ors (2009) regarding the application of multipliers and dependency deductions

Magma General Insurance Co. Ltd. v. Nanu Ram @ Chuhru Ram & Ors (2018) regarding the award of parental and filial consortium

The High Court found the Tribunal's assessment of ₹3,000/- monthly income to be insufficient. It determined that as per the Minimum Wages Notification applicable at the relevant time, the notional income should have been ₹7,930/-

Applying the Sarla Verma guidelines for a 55-year-old, the Court adopted a multiplier of 11 and a 1/3rd deduction for personal expenses

Following Pranay Sethi, the Court added 10% for "Future Prospects" and revised the "Funeral Expenses" to ₹30,000/-

Furthermore, per Magma General Insurance, the Court increased the "Loss of Consortium" to ₹40,000/- for each of the three claimants (totaling ₹1,20,000/-), whereas the Tribunal had only awarded a lump sum of ₹25,000/-

The Appellants are entitled to an additional amount of ₹6,03,624/- beyond the original award

The Court directed Respondent No. 3 (Insurance Company) to deposit the enhanced amount within 45 days, carrying interest at 7% per annum from the date of the claim application (01-07-2017) until realization

All other conditions of the original tribunal award remained intact