Spouse and each child are separately entitled to consortium compensation in fatal-accident claims.

On 27 February 2001, Karanji was fatally injured when a jeep, driven in reverse, struck him while he was waiting near the Government Guest House at Savli.

His widow and five children brought a claim under Section 166 of the Motor Vehicles Act, alleging that he was about 40 years old and earned ₹10,000 per month from sheep and goat breeding.

The Tribunal awarded ₹2,74,600 with 7.5% annual interest, adopting a monthly income of ₹2,400.

The claimants appealed, seeking enhancement; the income finding was not challenged by the insurer.

1. Whether the Tribunal’s assessment of compensation required enhancement by applying future prospects, a revised personal-expenses deduction and the appropriate multiplier.

2. Whether the claimants were entitled to revised compensation under the conventional heads, including consortium, loss of estate and funeral expenses.

Under Sections 166 and 173 of the Motor Vehicles Act, a claimant may seek just compensation for a motor-accident death, and an appeal lies against the Tribunal’s award.

The Court applied National Insurance Co. Ltd. v. Pranay Sethi, (2017) 16 SCC 680, for the principles governing future prospects, personal-expenses deductions, multipliers and conventional heads; it also relied on United India Insurance Co. Ltd. v. Satinder Kaur @ Satwinder Kaur, (2021) 11 SCC 780, concerning consortium.

The Court applied a 25% addition for future prospects, a one-fourth deduction for personal expenses where there were six dependants, and a multiplier of 15 for a deceased aged about 40.

It also applied the direction to increase conventional-head amounts by 10% every three years.

The Court upheld the Tribunal’s monthly income assessment of ₹2,400, noting that it was reasonable and had not been challenged by the insurer.

Because the deceased left a widow and five children, it considered the Tribunal’s one-third personal-expenses deduction excessive and substituted a one-fourth deduction.

It added 25% for future prospects, applied multiplier 15, and awarded consortium to each of the six dependants.

It further increased the conventional-head amounts in accordance with Pranay Sethi.

These adjustments produced total compensation of ₹7,64,370, while the Tribunal’s 7.5% interest rate was maintained.

The claimants became entitled to total compensation of ₹7,64,370, resulting in additional compensation of ₹4,89,770 over the original award, with 7.5% annual interest from the date of filing the claim petition until realization, and costs.

The insurer was directed to deposit the additional compensation before the Tribunal within eight weeks; the Tribunal was directed to disburse the amount to the claimants.