Siblings are ineligible for loss of love and affection; compensation is restricted to the three conventional heads.

On 28.10.2014, the deceased was riding a scooter when he was hit by a motorcycle ridden negligently by the second respondent.

The deceased succumbed to his injuries the same day.

The legal heirs (mother and three siblings) filed a claim before the Motor Accident Claims Tribunal (MACT), Kozhikode, which awarded ₹12,94,360/- as compensation.

The appellants approached the High Court seeking enhancement of the compensation, specifically challenging the notional income and the calculation of various heads of damages.

The court applied the principles from *Ramachandrappa v. Manager, Royal Sundaram Alliance Insurance Co. Ltd.*, fixing the notional income of a manual worker in 2014 at ₹9,500/- per month.

Regarding future prospects and multipliers, the court followed *National Insurance Co. Ltd. v. Pranay Sethi*, which mandates a 40% addition for future prospects for victims below 40 years and restricts compensation to three conventional heads: loss of estate, loss of consortium, and funeral expenses.

The court further relied on *Magma General Insurance Co. Ltd. v. Nanu Ram*, which categorized consortium into spousal, parental, and filial, and held that "loss of love and affection" is subsumed within "consortium" and cannot be a separate head.

Finally, it cited *V. Pathmavathi v. Bharathi Axa*, reinforcing that siblings are not recognized as beneficiaries for consortium.

The court found the Tribunal’s assessment of ₹5,000/- as monthly income inadequate, refixing it at ₹9,500/- based on the *Ramachandrappa* precedent for an electrician/plumber in 2014.

Applying *Pranay Sethi*, the court added 40% for future prospects and applied a multiplier of 18, resulting in a revised dependency loss of ₹14,36,400/-.

Regarding the ₹4,00,000/- awarded by the Tribunal for "loss of love and affection" to siblings, the court analyzed the *Magma General* and *Pathmavathi* rulings.

It determined that while parents are entitled to filial consortium and a spouse to spousal consortium, siblings do not have a legal entitlement to "consortium" or "love and affection" as distinct heads under current Supreme Court jurisprudence.

Consequently, the court reduced this award to ₹40,000/-, limited only to the mother for filial consortium.

The total compensation was enhanced from ₹12,94,360/- to ₹15,60,760/-, resulting in an additional award of ₹2,66,400/- with 9% interest per annum.

The court directed the insurer to deposit the enhanced amount within two months.