The High Court of Chhattisgarh has reaffirmed that findings of fact regarding the notional monthly income of a deceased, when based on uncontroverted pleadings and absent contrary documentary evidence, are not susceptible to interference in appeal. The judgment upholds established precedent regarding assessment of compensation in motor accident claims and remains binding on subordinate courts in the state.
Summary
| Category | Data |
|---|---|
| Case Name | MAC/353/2021 of LAJHRUS Vs SATYANARAYAN PRASAD |
| CNR | CGHC010159522021 |
| Date of Registration | 08-07-2021 |
| Decision Date | 15-10-2025 |
| Disposal Nature | DISMISSED |
| Judgment Author | HON’BLE SHRI JUSTICE RAKESH MOHAN PANDEY |
| Court | High Court of Chhattisgarh |
| Precedent Value | Binding within jurisdiction of Chhattisgarh High Court |
| Type of Law | Motor Accident Claims / Compensation Law |
| Questions of Law | Whether the assessment of notional monthly income of a deceased by the Claims Tribunal, in the absence of contradictory evidence, can be interfered with in appeal? |
| Ratio Decidendi |
The High Court found that the assessment of notional monthly income of the deceased as made by the Claims Tribunal constitutes a finding of fact, particularly where the insurer fails to lead evidence to controvert claimants’ pleadings. In the absence of any documentary or factual basis to challenge this finding, the interference in appeal is unwarranted. The award under conventional heads and application of future prospects and dependency deductions were found to be appropriate. Both appeals (by claimants for enhancement and insurer for reduction) were dismissed as misconceived. |
| Facts as Summarised by the Court |
The deceased died in a motor accident while working as a mason, with claimants pleading a monthly income of Rs. 15,000 (Rs. 500 per day). The insurance company failed to provide evidence contradicting this. The Tribunal awarded Rs. 28,30,000. Both claimants (for enhancement) and insurer (for reduction) appealed. |
Practical Impact
| Category | Impact |
|---|---|
| Binding On | All subordinate courts within the jurisdiction of Chhattisgarh High Court |
| Persuasive For | Other High Courts dealing with similar factual/pleading circumstances in MACT matters |
What’s New / What Lawyers Should Note
- Reaffirms that, in the absence of contrary evidence from the insurer, the Tribunal’s factual assessment of notional income based on uncontroverted pleadings is not open to appellate interference.
- Both appeals—by insurer challenging notional income, and by claimants seeking higher compensation under conventional heads—were held misconceived where findings below had factual basis and followed established methodology.
- Strengthens guidance to insurers: absence of rebuttal evidence to pleadings weakens appellate prospects.
Summary of Legal Reasoning
- The Court recorded that the claimants asserted a daily wage of Rs. 500 for the deceased and the insurer did not adduce any evidence to contradict this specific pleading.
- The Tribunal’s determination of the deceased’s notional monthly income is a factual finding.
- In appellate proceedings, such a factual finding cannot be interfered with in the absence of substantive contrary material.
- As the compensation awarded, including future prospects, dependency deduction, and amounts under conventional heads, was found appropriate, there was no scope for enhancement or reduction.
- Both appeals—by claimants (for enhancement) and insurer (for reduction)—lacked merit and were dismissed.
Arguments by the Parties
Petitioner (Claimants):
- Tribunal assessed notional monthly income on lower side.
- Tribunal awarded meager amounts under conventional heads.
- Sought modification/enhancement of award.
Respondent (Insurance Company):
- Tribunal assessed monthly income at Rs. 15,000 in absence of documentary evidence.
- Asserted this contravened the minimum wage matrix applicable in Chhattisgarh at the time.
- Sought modification of the award.
Factual Background
The case arose from the death of Rajeshwar in a motor accident on 29.3.2019, when he was struck by a mini-truck driven in a rash and negligent manner. His parents, wife, and children filed a claim, asserting his occupation as a mason with monthly earnings of Rs. 15,000. The insurance company, driver, and owner contested the claim, but did not produce contrary evidence regarding income. The Tribunal awarded Rs. 28,30,000. Both claimants (seeking enhancement) and the insurance company (seeking reduction) appealed.
Statutory Analysis
The Court examined principles pertaining to assessment of notional income in the absence of documentary evidence, the application of deductions for personal expenses, and the award of future prospects and conventional heads under the Motor Vehicles Act as applied in compensation claims. The judgment did not explicitly interpret or “read down” any section but reaffirmed settled approaches on factual determinations in the motor accident compensation context.
Alert Indicators
- ✔ Precedent Followed – The decision reaffirms and follows existing precedent concerning appellate interference with factual findings of MACTs on income assessment and compensation.