Notional income must align with Minimum Wages Notifications and statutory updates for just compensation enhancement.

The appellants (parents of the deceased) filed an appeal under Section 173 of the Motor Vehicles Act, 1988, seeking enhancement of a compensation award dated 11.11.2019

The Claims Tribunal had previously awarded a total sum of Rs. 12,97,720/- following a motor accident involving a "Swaraj Majada" vehicle

The appellants contended that the Tribunal erred by assessing the deceased’s monthly income at Rs. 8,100/- instead of the Rs. 8,750/- prescribed by the Chhattisgarh Minimum Wages Notification and failed to award just amounts for loss of estate, consortium, and funeral expenses

1. Whether the monthly income of the deceased was correctly assessed by the Tribunal in accordance with the Chhattisgarh Minimum Wages Notification.

2. Whether the compensation awarded under conventional heads (loss of estate, funeral expenses, and consortium) required enhancement in line with prevailing judicial precedents.

The Court applied the statutory framework of the Motor Vehicles Act, 1988

The minimum wage rates prescribed by the Office of the Labour Commissioner, Chhattisgarh

Formulaic principles for calculating "just compensation" established by the Supreme Court in National Insurance Company Ltd. v. Pranay Sethi (2017) regarding future prospects and conventional heads

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

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

The High Court determined that the Tribunal’s assessment of Rs. 8,100/- per month was undervalued and adjusted it to Rs. 8,750/- per month based on the Minimum Wages Notification at the relevant time

Applying the Pranay Sethi and Sarla Verma guidelines, the Court added 40% for future prospects and deducted 1/2 for personal expenses given the deceased's status (implied), resulting in a monthly contribution of Rs. 73,500/- per annum, which was then multiplied by 18

The Court found the conventional heads were underpaid; it enhanced funeral expenses and loss of estate from Rs. 15,000/- to Rs. 18,000/- each, and adjusted the loss of consortium to Rs. 44,000/- per appellant (totaling Rs. 88,000/-) to reflect the 10% incremental increase over original limits as per standard practice

The Respondent Insurance Company was directed to deposit the enhanced amount of Rs. 1,52,280/- within 45 days, carrying interest at 6% per annum from the date of the claim application