Widow And Sons’ Bid To Raise ₹14.8 Lakh Accident Award Fails As Chhattisgarh HC Finds No Proof Deceased Earned ₹12,000 A Month As Mason

In brief

The question

Whether the deceased’s monthly income should be reassessed at ₹12,000, as claimed, and the compensation enhanced accordingly

The court held

The Court held that there was no legal or factual infirmity in the Tribunal’s award and dismissed the appeal at the admission stage.

It also directed

The award of ₹14,80,000 therefore remained undisturbed

The 85-day delay in filing the appeal had separately been condoned.

01Facts

The appellants, dependants of Jailal Matlam, challenged the Motor Accident Claims Tribunal, Raipur’s award dated 20 March 2026, which granted ₹14,80,000 for his death in a motor vehicle accident on 14 September 2023.

¶ 5

They sought enhancement, contending that the deceased, who worked as a mason, earned ₹12,000 per month rather than the ₹10,000 monthly income assessed by the Tribunal

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The High Court first allowed the appellants’ application to condone an 85-day delay in filing the appeal

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02Issues

i.Whether the deceased’s monthly income should be reassessed at ₹12,000, as claimed, and the compensation enhanced accordingly

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ii.Whether the Tribunal’s award contained a legal or factual infirmity warranting appellate interference

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03Law Applied

The judgment identifies no specific statutory provision or binding precedent as the basis for its decision.

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It applies the principles used to assess dependency compensation: consideration of the deceased’s income, addition for future prospects, deduction for personal and living expenses based on the number of dependants, application of an age-appropriate multiplier, and award under conventional heads.

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The Court also considered the applicable minimum-wage notification, which prescribed ₹9,960 per month for an unskilled labourer at the time of the accident.

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The appellants’ reliance on Chandra Kala & Ors. v. ICICI Lombard Motor Insurance Co. Ltd. & Ors., 2025 LawSuit (SC) 1400, was noted but not adopted as a basis for the decision.

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04Reasoning

The Court found that the Tribunal’s assessment of ₹10,000 per month was consistent with the applicable minimum wage of ₹9,960.

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The appellants had produced no cogent or reliable evidence before the Tribunal to establish either the deceased’s occupation as a mason or his claimed income of ₹12,000 per month.

¶ 8

The Tribunal had also applied a 30% addition for future prospects, deducted one-third for personal expenses, used a multiplier of 13 for the deceased’s age group, and awarded ₹1,80,000 under conventional heads.

¶ 8

In the absence of evidence or other material showing error in those assessments, the Court found the compensation fair and proper.

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