Without evidence of higher earnings, compensation based on applicable minimum wages cannot be enhanced.

The appellants—widow, two minor children, and mother of the deceased Kirti Kumar Verma—filed an appeal seeking enhancement of compensation awarded by the 10th Additional Motor Accident Claims Tribunal, Bilaspur, in Motor Accident Claim Case No. 1623/2021.

Kirti Kumar Verma died from injuries sustained in a motor vehicle accident on 30 May 2021.

The Tribunal awarded total compensation of ₹20,62,220 by assessing his monthly income at ₹9,200, adding 40% towards future prospects, deducting one-fourth towards personal and living expenses, applying a multiplier of 16, and awarding ₹1,63,500 under conventional heads.

The appeal was filed with a delay of 21 days, which the High Court condoned for sufficient reasons.

The appellants contended that the deceased’s income had been assessed too low, while the insurer supported the Tribunal’s award.

Whether the deceased’s monthly income should have been assessed at an amount higher than ₹9,200 for the purpose of computing compensation?

Whether the compensation of ₹20,62,220 awarded by the Tribunal required enhancement on account of an erroneous assessment of income or computation?

The Court applied the established principles governing computation of compensation in fatal motor accident claims: income must be assessed on the basis of reliable evidence and the applicable minimum-wage notification; future prospects may be added according to the deceased’s age and employment circumstances; a deduction is made towards the deceased’s personal and living expenses based on the number of dependants; and the appropriate multiplier is selected with reference to the deceased’s age.

On the facts, the Court accepted the minimum monthly wage of ₹9,200 for an unskilled labourer, a 40% addition for future prospects, a one-fourth deduction for personal expenses, and a multiplier of 16 for the deceased’s age group.

The Court found that the accident occurred on 30 May 2021, when the applicable minimum wage for an unskilled labourer was ₹9,200 per month.

The appellants produced no material establishing that Kirti Kumar Verma was a skilled labourer or earned more than the prescribed minimum wage; therefore, there was no evidentiary basis for increasing his income.

The Court further held that the Tribunal had correctly added 40% for future prospects, deducted one-fourth for personal and living expenses in view of four claimants, applied the multiplier of 16 corresponding to the deceased’s age bracket, and awarded ₹1,63,500 under conventional heads.

Since the computation disclosed no legal or factual error, the Court declined to interfere.

It held that the deceased’s income was correctly assessed at ₹9,200 per month and that the Tribunal had properly calculated the compensation at ₹20,62,220.

Finding no legal or factual infirmity in the award, the Court dismissed the claimants’ appeal for enhancement at the admission stage.