Tribunal must award just compensation based on minimum wages regardless of lower income pleaded by claimants.

On December 28, 2017, Vishnubhai Maheshbhai Vasava (the deceased) was riding a motorcycle when he was struck by a tractor driven at excessive speed.

The deceased succumbed to his injuries.

The Motor Accident Claims Tribunal (MACT), Vadodara, partly allowed the claim, awarding Rs. 8,59,000/- with 7.5% interest.

The MACT assessed the deceased’s monthly income at Rs. 5,000/- based on the claimants' original pleadings, despite the deceased being an agricultural worker.

The claimants appealed to the High Court seeking enhancement of compensation, arguing that the income assessment was lower than the prevailing minimum wages and that conventional heads were inadequately compensated.

1. Whether the Tribunal is bound by the income pleaded in the claim petition if it is lower than the statutory minimum wages prevalent at the time of the accident.

2. Whether the appellants are entitled to enhanced compensation under conventional heads such as loss of estate, funeral expenses, and consortium.

The court applied the principle of "just compensation" under the Motor Vehicles Act.

Rajesh v. Rajbir Singh [(2013) 9 SCC 54], which mandates that Tribunals must award fair compensation regardless of the specific claims made in an application.

Hitesh Nagjibhai Patel v. Bababhai Nagjibhai Rabari [2025 AIJEL-SC 75833], which directs Tribunals to use minimum wage data for skilled workers to calculate income when proof is lacking.

National Insurance Co. Ltd. v. Pranay Sethi [(2017) 16 SCC 680] and Magma General Insurance Co. Ltd. v. Nanu Ram @ Chuhru Ram [(2018) 18 SCC 130].

The court reasoned that determining compensation is not strictly governed by pleadings; rather, the judiciary has a duty to ensure "just, equitable, and fair" amounts.

Although the claimants pleaded an income of Rs. 5,000/-, the court found that the minimum wage for a skilled worker in Gujarat at the time of the 2017 accident was Rs. 8,388/- per month.

Applying the Pranay Sethi framework, the court added 40% for future prospects (as the deceased was 19 years old) and deducted 1/2 for personal expenses (as he was a bachelor), resulting in a loss of dependency of Rs. 12,68,352/-.

The court also corrected the "meagre" awards for conventional heads, increasing funeral expenses and loss of estate to Rs. 18,150/- each and awarding parental consortium of Rs. 48,400/- to each parent (totaling Rs. 96,800/-).

The High Court partly allowed the appeal, increasing the total compensation from Rs. 8,59,000/- to Rs. 14,31,452/-.

The Respondent-Insurance Company was directed to deposit the additional amount of Rs. 5,72,452/- with 7.5% interest per annum within six weeks.

The Tribunal was ordered to disburse the amount to the claimants after verifying court fees.