Delhi High Court

Vouchers and eyewitness testimony are sufficient evidence to establish deceased's income beyond minimum wage standards.

Shriram General Insurance Co. Ltd. v. Naushad Naz & Ors. MAC.APP. 92/2026

Delhi High CourtJUDGMENT: no citation2 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The Appellant Insurance Company challenged the Motor Accident Claims Tribunal (MACT) Award dated 14th October 2024

Source reference: para 1

The MACT had awarded compensation of Rs. 28,90,300 to the respondents (legal heirs of the deceased) for a motor accident

Source reference: para 1

However, in its final computation, the MACT added interest to the principal and then erroneously directed 9% interest to be paid on that combined sum (effectively interest on interest)

Source reference: para 2

Additionally, the Appellant challenged the assessment of the deceased's monthly income at Rs. 15,000, arguing it should have been based on minimum wages

Source reference: para 5
02

Issues

Whether the MACT erred in its calculation by applying interest on a sum that already included interest component?

Source reference: para 2

Whether the evidence on record was sufficient to sustain a finding of a monthly income of Rs. 15,000 for the deceased?

Source reference: para 5
03

Law Applied

The court applied principles governing the computation of compensation under the Motor Vehicles Act, 1988, specifically regarding the determination of "just compensation" based on proven income rather than minimum wages when robust evidence is available

Source reference: para 10

It also applied the principle that interest is typically calculated on the principal compensation amount from the date of filing the petition until realization to avoid double computation or interest-on-interest

Source reference: para 3
04

Reasoning

Regarding the calculation error, the Court found that the MACT’s paragraph 35 created confusion by stating a total of Rs. 47,58,821 (Principal + Interest) was subject to further 9% interest; the Court clarified that interest must only be calculated on the principal sum of Rs. 28,90,300

Source reference: para 3

Regarding income, the Court reviewed the testimony of PW-3 (the widow) and PW-4 (the employer/proprietor of S.K. Tailors)

Source reference: paras 6, 8

The evidence established that the deceased was a skilled "tailor master/karigar"

Source reference: para 9

The Court specifically relied on salary voucher receipts (Ex. PW-2/1) which showed a salary increase from Rs. 12,000 to Rs. 15,000

Source reference: para 9

The Court concluded that since the testimony remained unshaken during cross-examination and was supported by documentary evidence, the benchmark of Rs. 15,000 was "robust, substantial and sufficient"

Source reference: para 10
05

Holding

The High Court partly allowed the appeal by modifying the Award to correct the interest duplication

It held that the compensation of Rs. 28,90,300 shall bear interest at 9% per annum from the date of filing until realization, dismissing the calculation in paragraph 33 of the original award

Source reference: para 3

The Court upheld the MACT’s assessment of the deceased's income at Rs. 15,000 per month

Source reference: para 10

The appeal was disposed of, and the statutory deposit was ordered to be refunded to the Appellant

Source reference: para 14
Delhi High Court

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Shriram General Insurance Co. Ltd. v. Naushad Naz & Ors. MAC.APP. 92/2026

Delhi High Court · no citation

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