Prevailing minimum wages must govern income assessment for compensation where documentary proof of income is absent.

The appellants (claimants) filed an appeal under Section 173(1) of the Motor Vehicles Act, 1988, challenging the award dated 26.07.2021 passed by the Motor Accident Claims Tribunal (MACT), Gwalior, in Claim Case No. 130/2019.

The claim arose from the death of an individual named Mukesh in a motor vehicle accident.

The MACT initially awarded compensation of Rs. 17,90,600.

The appellants sought enhancement on the grounds that the Tribunal failed to properly appreciate the deceased's income and omitted just compensation under conventional heads such as loss of love and affection and funeral expenses.

The facts regarding the accident, negligence, and liability were not in dispute.

1. Whether the income of the deceased was correctly assessed in the absence of documentary evidence.

2. Whether the claimants were entitled to enhanced compensation under the heads of future prospects, multiplier application, and conventional heads.

The court applied Section 173(1) of the Motor Vehicles Act, 1988, for the maintainability of the appeal.

Regarding income assessment in the absence of documentary proof, the court relied on the Minimum Wages Act and precedents including Sukhdevi v. Devendra Kumar and National Insurance Co. Ltd. v. Renu Devi, which mandate assessment based on minimum wages.

For the computation of future prospects, the court applied the mandate of National Insurance Co. Ltd. v. Pranay Sethi.

The selection of the multiplier was governed by Sarla Verma v. Delhi Transport Corporation.

Finally, the court applied United India Insurance Co. Ltd. v. Satinder Kaur to determine the distribution of consortium, loss of estate, and funeral expenses.

The Court observed that the claimants failed to produce substantial evidence regarding the deceased's specific income; thus, it assessed the income as a "skilled person" under the Minimum Wages Act at Rs. 9,610 per month.

Applying the Pranay Sethi doctrine, the Court added 40% for future prospects and upheld the 1/4 deduction for personal expenses.

Following the Sarla Verma guidelines, a multiplier of 17 was applied based on the age of the deceased.

For conventional heads, the Court followed Satinder Kaur, awarding Rs. 40,000 each to five claimants for consortium (Rs. 2,00,000 total) and Rs. 30,000 for funeral expenses and loss of estate.

By applying these legal standards to the facts, the Court recalculated the total compensation to be Rs. 22,88,462, finding the Tribunal's original award of Rs. 17,90,600 to be inadequate.

It held that the claimants are entitled to an additional compensation of Rs. 4,97,862 over and above the original award, totaling Rs. 22,88,462.

The Court ordered that the enhanced amount shall carry interest as fixed by the Tribunal and directed the Insurance Company to deposit the amount within three months.

The appellants were further directed to pay any differential Court fees if the enhanced amount exceeded the initial valuation of the appeal.