Spousal, parental, and filial consortium must be awarded separately to eligible claimants.

Narendra Kumar Netam died in a motor-vehicle accident on 3 November 2024.

His wife, minor daughter and mother filed a claim petition under the Motor Vehicles Act, 1988.

The Claims Tribunal, in Claim Case No. 14/2025, awarded total compensation of ₹16,96,800 by award dated 10 November 2025.

Under the conventional heads, it awarded ₹18,000 towards loss of estate, ₹18,000 towards funeral expenses and ₹48,000 as spousal consortium only to the widow, aggregating to ₹84,000.

The claimants preferred an appeal under Section 173 of the Motor Vehicles Act seeking enhancement, principally on the ground that consortium had not been awarded to the minor daughter and the deceased’s mother.

Whether the minor daughter and the deceased’s mother were entitled to parental and filial consortium, respectively, in addition to the spousal consortium awarded to the widow?

Whether the compensation awarded under the conventional heads was required to be enhanced in accordance with the principles laid down in National Insurance Co. Ltd. v. Pranay Sethi?

The Court exercised appellate jurisdiction under Section 173 of the Motor Vehicles Act, 1988, which permits an appeal against an award of the Claims Tribunal.

It applied the principles in National Insurance Co. Ltd. v. Pranay Sethi, (2017) 16 SCC 680, including the award of consortium to eligible family members and the periodic enhancement of amounts under the conventional heads.

The Court recognised spousal, parental and filial consortium as compensable heads and awarded ₹48,000 to each claimant, reflecting the 20% increase adopted with reference to the date of accident and the Pranay Sethi guidelines.

The Tribunal had awarded consortium only to the deceased’s wife and had omitted any amount for the minor daughter and the mother.

Since all three were claimants and were entitled to the benefit of the applicable consortium principles, the High Court held that the omission resulted in an inadequate award under that head.

It therefore recalculated consortium at ₹48,000 each for the widow, daughter and mother, totalling ₹1,44,000, while leaving the amounts awarded for loss of estate and funeral expenses undisturbed.

As ₹48,000 had already been awarded by the Tribunal towards consortium, the Court granted an additional ₹96,000.

The claimants were held entitled to an additional ₹96,000 towards consortium, making the total consortium compensation ₹1,44,000—₹48,000 each for the widow, minor daughter and mother.

The enhanced amount was directed to carry interest at 6% per annum from the date of filing of the claim petition until realisation.

The Tribunal’s award was modified to that extent, with the remaining conditions left intact.

The Registry was also directed to communicate the enhanced amount to the claimants in Hindi Devanagari, with assistance from paralegal workers where necessary.