Objective assessment of notional income for qualified professionals must consider educational qualifications and future career prospects.

The appellants, original claimants (the widow, parents, and sister of the deceased), challenged the judgment and award dated 07.02.2014 passed by the Motor Accident Claims Tribunal (MACT), Banaskantha at Palanpur.

The deceased, aged 21 years and a qualified Mechanical Engineer holding a first-class diploma and a petrol pump dealership, died in a motor vehicle accident in 1996.

The Tribunal awarded a total compensation of ₹5,02,000/- with 8.5% interest, assessing the deceased’s income at a minimum wage of ₹2,000/- per month.

The appellants sought enhancement, arguing the income assessment was too low given his qualifications and future prospects.

1. Whether the Tribunal erred in assessing the notional monthly income of the deceased at ₹2,000/- instead of ₹5,000/- based on his professional qualifications and business interests.

2. Whether the compensation under conventional heads and future prospects was adequately awarded as per current legal standards.

Section 166 and Section 173 of the Motor Vehicles Act, 1988.

The Court relied on National Insurance Company Ltd. v. Pranay Sethi [(2017) 16 SCC 680] to determine future prospects (50% for self-employed under 40 years) and standardized conventional heads.

It followed Sarla Verma v. Delhi Transport Corp. [(2009) 6 SCC 121] for the application of the multiplier (18 for age 21) and deduction for personal expenses (1/3rd).

Additionally, it utilized the precedent of Narender Dev Poonia v. Hasan Mohd. [2026 (0) ACJ 80] to justify a higher notional income for qualified engineers even in the absence of salary slips.

The Court observed that the Tribunal failed to objectively assess the deceased’s potential, relying erroneously on minimum wages despite evidence of a first-class Diploma in Mechanical Engineering, a petrol pump dealership (Exh. 50), and a PAN card (Exh. 51).

Considering the "bright future" of the 21-year-old qualified professional, the Court increased the notional monthly income to ₹5,000/-.

Applying Pranay Sethi, the Court added 50% for future prospects, totaling ₹7,500/- per month, and deducted 1/3rd for personal expenses.

The multiplier of 18 was upheld, resulting in dependency loss of ₹10,80,000/-.

Regarding conventional heads, the Court adjusted figures for inflation and precedent: parental consortium was increased to ₹40,000 each (plus 10% enhancement, totaling ₹48,400 per parent), and awarded ₹50,000 for love and affection to the sister and remarried widow.

The Court held that the claimants are entitled to the enhanced amount of ₹7,61,100/- with interest at 8.5% per annum from the date of the claim petition until realization.

The respondent Insurance Company was directed to deposit the enhanced amount within six weeks, with the Tribunal ordered to disburse the funds upon verification.