Parental consortium compensation includes the applicable statutory enhancement.

The appeal arose from a motor accident on 4 September 2020 in which Sukho Bai Yadav, aged about 90, died.

The Claims Tribunal assessed her notional income at ₹4,500 per month, found no loss of dependency, and awarded her son ₹73,000 under conventional heads.

The son appealed under Section 173 of the Motor Vehicles Act, 1988, seeking enhancement on the basis that the deceased’s income had been assessed too low.

Whether the Tribunal’s award of ₹73,000 required enhancement in light of the deceased’s age, income assessment, and the applicable conventional heads of compensation.

Whether the claimant was entitled to interest on any enhanced compensation and, if so, from what date.

The appeal was brought under Section 173 of the Motor Vehicles Act, 1988, which provides for an appeal against a Claims Tribunal award.

The judgment applied the stated principles governing compensation under conventional heads, including loss of estate, funeral expenses, and consortium, with statutory enhancement; it also treated future prospects and a multiplier as inapplicable in this case given the deceased’s age of 90.

The Court accepted the Tribunal’s assessment of notional income and its conclusion that no dependency loss was payable, given the deceased’s age and the absence of dependent legal representatives.

It nevertheless enhanced the award, holding that the claimant was entitled to ₹16,500 for loss of estate, ₹16,500 for funeral expenses, and ₹44,000 for parental consortium.

The judgment then fixed total compensation at ₹1,25,000, but does not explain how that total follows from the listed heads, which add up to ₹77,000; nor does it identify an additional component accounting for the difference.

The remaining terms of the Tribunal’s award were left intact.

The Registry was directed to notify the claimant in Hindi, with paralegal assistance if required.