Salary certificate corroborated by employer's testimony and vehicle records constitutes reliable evidence for assessing deceased's income.

The appellants, parents of the deceased Ravishankar Sahu, filed a claim under Section 166 of the Motor Vehicles Act, 1988, following a fatal accident on 16.07.2020

The deceased was driving a Swaraj Mazda (CG-10-X-2187) when it was struck by an offending truck (MP-20-HB-4067) owned by Respondent No. 1 and insured by Respondent No. 2

The claimants asserted the deceased was a driver earning Rs. 18,000 per month.

The owner of the Mazda (AW-2) testified that the deceased had been his employee for five years, earning a monthly salary of Rs. 14,000 plus diet money, and produced a salary certificate (Ex. P/9)

The Tribunal awarded a total compensation of Rs. 16,65,848, which the appellants challenged as inadequate, specifically contesting the lower assessment of the deceased's monthly income

1. Whether a salary certificate issued by a private employer can be relied upon for income assessment in a motor accident claim when corroborated by oral testimony and the circumstances of the accident.

2. Whether the compensation awarded by the Tribunal requires enhancement based on the established skill and employment of the deceased.

The Court applied Sections 166 and 173 of the Motor Vehicles Act, 1988.

It relied on the principles for calculating "just compensation" established in National Insurance Company Ltd. v. Pranay Sethi (2017) 16 SCC 680 regarding future prospects (40% for the deceased's age group)

It followed Sarla Verma v. Delhi Transport Corporation (2009) 6 SCC 121 for determining the appropriate multiplier (18) and personal expenditure deductions (1/2 for a bachelor)

Additionally, it applied Magma General Insurance Co. Ltd. v. Nanu Ram @ Chuhru Ram (2018) 18 SCC 130 to award filial consortium to the parents

The Court scrutinized the reliability of the salary certificate (Ex. P/9). While acknowledging that solitary certificates are often insufficient, the Court found the "factual matrix" of this case unique: the deceased died while driving the very vehicle owned by the witness (AW-2) who issued the certificate

The Court performed an independent online verification of the vehicle's registration to confirm AW-2 was indeed the owner

Given that the deceased was a skilled worker (holding a valid driving license) and the employer personally deposed to his five-year tenure and salary, the Court held the reported income of Rs. 14,000 per month to be reliable

Consequently, the Court recalculated the dependency by adding 40% for future prospects, applying a multiplier of 18, and deducting 50% for personal expenses, finding the Tribunal’s original assessment to be undervalued

The claimants were held entitled to an additional amount of Rs. 5,60,952 with 6% interest per annum from the date of the appeal's filing (31.07.2023)

The Court directed the Insurance Company to deposit the enhanced amount within 60 days, with specific instructions to place Rs. 2,50,000 each in fixed deposits for the parents and release the remainder to the mother