Chhattisgarh High Court
Insurance LawCivil Law

The multiplier is determined by completed age; a deceased aged 45 attracts multiplier 14.

UNITED INDIA INSURANCE CO. LTD. vs SAWAN BARLA

Chhattisgarh High CourtJUDGMENT: October 01, 20262 MIN READSOURCE JUDGMENT
The multiplier is determined by completed age; a deceased aged 45 attracts multiplier 14.. UNITED INDIA INSURANCE CO. LTD. vs SAWAN BARLA. Chhattisgarh High Court. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The appeals arose from a motor accident claim award concerning the death of Anup Kumar Barla in a road accident on 19 July 2022.

Source reference: para. 2–4

The Claims Tribunal awarded ₹84,62,520 in compensation.

Source reference: para. 2–4

The insurer appealed, contending that income tax should have been deducted from the deceased’s income; the claimants appealed, challenging the multiplier of 13 and seeking enhanced conventional damages.

Source reference: para. 2–4

The deceased’s date of birth was 1 July 1977, making him 45 years and 18 days old at the time of the accident.

Source reference: para. 6
02

Issues

Whether the Tribunal correctly applied a multiplier of 13, or whether the deceased’s completed age of 45 years required a multiplier of 14.

Source reference: para. 4, 6–8

Whether income tax was required to be deducted from the deceased’s income when calculating dependency compensation.

Source reference: para. 3, 8–11

Whether the amount awarded under conventional heads required enhancement.

Source reference: para. 8
03

Law Applied

Under Sarla Verma v. Delhi Transport Corporation, the applicable multiplier is determined by the deceased’s age category; for ages 41–45, the multiplier is 14.

Source reference: para. 4

Shashikala v. Gangalakshmamma confirms that completed years of age govern multiplier selection.

Source reference: para. 7

Under National Insurance Co. Ltd. v. Pranay Sethi, future prospects and conventional heads are assessed in accordance with the applicable principles.

Source reference: para. 8–9, 12

The Court also relied on Magma General Insurance Co. Ltd. v. Nanu Ram in computing conventional compensation.

Source reference: para. 12

The Court held that income tax was to be deducted from the deceased’s annual income using the applicable FY 2022–23 tax slabs.

Source reference: para. 8, 10–11
04

Reasoning

The deceased had completed 45 years, but not 46; applying Shashikala and Sarla Verma, the Court held that the proper multiplier was 14, not 13.

Source reference: para. 6–8

It accepted the Tribunal’s undisputed monthly income of ₹61,779, added 30% for future prospects, and calculated annual income at ₹9,63,752.

Source reference: para. 8–9

Applying the FY 2022–23 tax slabs, it deducted ₹1,09,460 in tax, leaving annual income of ₹8,54,292; after deducting one-third for personal expenses and applying multiplier 14, loss of dependency was ₹79,73,392.

Source reference: para. 10–12

The Court enhanced conventional heads to ₹1,21,000.

Source reference: para. 8, 12
05

Holding

The Court partly allowed both appeals and modified the award.

It recalculated total compensation at ₹80,94,392, replacing the Tribunal’s award of ₹84,62,520; the remaining conditions of the award were left intact.

Source reference: para. 13–14
06

Acts & Sections Cited

1 provisions across 1 statute referred to in this judgment. Each provision opens on LawLens.

Motor Vehicles Act, 19881

Chhattisgarh High Court

Original Court PDF

UNITED INDIA INSURANCE CO. LTD.vsSAWAN BARLA

Chhattisgarh High Court · October 01, 2026

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