Summary
| Category | Data |
|---|---|
| Court | Supreme Court of India |
| Case Number | C.A. No.-014756-014756 – 2025 |
| Diary Number | 1108/2024 |
| Judge Name | HON’BLE MR. JUSTICE K. VINOD CHANDRAN |
| Bench |
|
| Precedent Value | Binding |
| Overrules / Affirms |
|
| Type of Law | Motor Accident Claims / Compensation law |
| Questions of Law |
|
| Ratio Decidendi | The Court held that for a fatality claim by parents of a deceased minor, notional monthly income at minimum-wage rates under the Minimum Wages Act, 1948, may be adopted. A 40% uplift for future prospects and a multiplier of 15 (per Reshma Kumari) apply. A 50% deduction for personal expenses is mandatory. The decision distinguishes disability cases (where an 18 multiplier may apply) from death claims and confirms additional heads: loss of estate, filial consortium, medical and funeral expenses, and a separate award for pain and suffering. |
| Judgments Relied Upon |
|
| Logic / Jurisprudence / Authorities Relied Upon by the Court | Use of statutory minimum wages as a reliable basis for notional income; precedents on multiplier selection and components of compensation for death vs. disability. |
| Facts as Summarised by the Court | A 14-year-old boy was fatally injured when a rashly driven truck struck him and two classmates. The parents’ claim before the Motor Accident Claims Tribunal resulted in Rs. 1,29,500; the High Court enhanced it to Rs. 4,70,000. The appellants sought further enhancement based on higher multipliers and contemporaries’ earning evidence. |
Practical Impact
| Category | Impact |
|---|---|
| Binding On | All subordinate courts |
| Distinguishes | Baby Sakshi Greola v. Manzoor Ahmad Simon & Anr. (2024 INSC 963) |
| Follows | Reshma Kumari v. Madan Mohan (2013 SCC OnLine SC 284) |
What’s New / What Lawyers Should Note
- The Court confirms that monthly notional income for dependency in a fatality claim may be based on the statutory minimum wages for a Class B city (Rs. 5,400).
- Future prospects uplift fixed at 40% and a multiplier of 15 must be applied for a minor’s death claim.
- A 50% deduction for personal living expenses is mandatory.
- Pain and suffering of the deceased prior to death can be separately compensated and inures to the legal heirs.
- Distinguishes the multiplier in death claims (15) from disability claims (18 in Baby Sakshi Greola).
Summary of Legal Reasoning
- Both parties agreed to adopt minimum wages under the Minimum Wages Act, 1948, as notional income for a Class B city (Rs. 5,400 per month).
- A 40% increase was applied for future prospects.
- The multiplier of 15 was adopted, following Reshma Kumari.
- A 50% deduction for personal and living expenses was applied.
- The Court distinguished disability-based compensation (multiplier 18 in Baby Sakshi Greola) from fatality claims.
- Additional heads (medical expenses, loss of estate, funeral expenses, filial consortium, and pain and suffering) were awarded as per established practice.
Arguments by the Parties
Petitioner
- Relied on contemporaries’ earning evidence to argue for a higher multiplier (18) as in Baby Sakshi Greola.
- Contended that the High Court’s criterion was inadequate.
Respondent
- Agreed to adopt minimum wages for notional income.
- Submitted that the multiplier must remain at 15, as held in Reshma Kumari.
Factual Background
A 14-year-old schoolboy and two classmates were struck by a negligently driven truck; the two classmates died instantly and the boy died a day later in hospital. The Motor Accident Claims Tribunal awarded Rs. 1,29,500 with 6% interest; the High Court enhanced the award to Rs. 4,70,000 with 6% interest. The parents appealed to the Supreme Court for further enhancement, focusing on notional income basis and choice of multiplier.
Statutory Analysis
- Minimum Wages Act, 1948: Adopted to compute notional income for dependency.
- Motor Vehicles Act principles on compensation guided the Court, but no novel statutory interpretation beyond established precedents was required.
Alert Indicators
- ✔ Precedent Followed – Confirms Reshma Kumari parameters for multiplier and deductions.
- 🔄 Conflicting Decisions – Distinguishes from Baby Sakshi Greola’s application of an 18-year multiplier in disability cases.