High Court upholds the Motor Accident Claims Tribunal’s (MACT) factual findings on notional income and compensation quantum where no documentary evidence is led to the contrary, reaffirming limited appellate interference; binding on subordinate courts adjudicating similar compensation claims.
Summary
| Category | Data |
|---|---|
| Case Name | MAC/279/2021 of DIVISIONAL MANAGER Vs LAZRUS |
| CNR | CGHC010105902021 |
| Date of Registration | 16-06-2021 |
| Decision Date | 15-10-2025 |
| Disposal Nature | DISMISSED |
| Judgment Author | Hon’ble Shri Justice Rakesh Mohan Pandey |
| Court | High Court of Chhattisgarh |
| Bench | Single Judge (Hon’ble Shri Justice Rakesh Mohan Pandey) |
| Precedent Value | Binding on subordinate courts within Chhattisgarh; persuasive elsewhere |
| Overrules / Affirms | Affirms MACT’s award; does not overrule prior precedent |
| Type of Law | Motor Vehicle Accident Compensation (Civil) |
| Questions of Law | Whether the High Court can interfere with the Tribunal’s factual findings on notional income and compensation in the absence of contrary documentary evidence? |
| Ratio Decidendi |
The Court held that the assessment of notional income by the Tribunal based on pleadings, where the insurance company led no evidence to the contrary, is a finding of fact. In such cases, the High Court cannot interfere with the Tribunal’s finding in appellate jurisdiction. The compensation awarded under conventional heads and the calculation for future prospects and personal/living expenses were found appropriate by the Court. Both appeals (one seeking enhancement, the other reduction) were dismissed as misconceived due to lack of material infirmity. The decision reaffirms limited scope of appellate review in factual matters absent perversity or legal error. |
| Judgments Relied Upon | Not specified in the judgment |
| Logic / Jurisprudence / Authorities Relied Upon | Principle of appellate restraint in interfering with findings of fact in absence of contrary evidence. |
| Facts as Summarised by the Court |
Deceased Rajeshwar died in a road accident; claimants pleaded his income as Rs. 500 per day as mason; Insurance Company did not lead evidence to the contrary; Tribunal fixed notional monthly income at Rs. 15,000 and awarded Rs. 28,30,000 in compensation. Both claimants and insurer appealed, disputing quantum. |
Practical Impact
| Category | Impact |
|---|---|
| Binding On | Subordinate courts and tribunals within Chhattisgarh |
| Persuasive For | Motor Accident Claims Tribunals and courts in other jurisdictions |
| Overrules | None |
| Distinguishes | None |
| Follows | Principle of non-interference with factual findings absent contrary evidence |
What’s New / What Lawyers Should Note
- Reaffirms that appellate courts will not disturb Tribunal findings on notional income when the opposing party has not led any evidence to negate claimants’ pleadings.
- Establishes that compensation quantum under conventional heads, future prospects, personal and living expenses, will not be revisited in appellate proceedings unless proven erroneous or perverse with evidence.
- Both enhancement and reduction of compensation claims are liable to be dismissed when Tribunal’s computation follows established principles and is based on available pleadings and materials.
- Lawyers should ensure documentary evidence is marshalled at the Tribunal stage if factual findings on income or dependency are to be contested.
Summary of Legal Reasoning
- The High Court examined whether the Motor Accident Claims Tribunal’s finding on the deceased’s notional income (Rs. 15,000/month as mason) could be interfered with on appeal.
- It noted that the insurance company had not produced any documentary evidence to contradict the claimants’ pleadings regarding income.
- The Court held such a finding is factual, and absent contrary evidence or demonstrated perversity, cannot be interfered with by the appellate court.
- On the issue of quantum—including future prospects, personal and living expenses deduction, and compensation under conventional heads—the High Court found the Tribunal had applied correct legal tests and appropriate multipliers.
- Accordingly, both the claimants’ and insurer’s appeals, one seeking enhancement and the other reduction, were found devoid of merit and dismissed.
Arguments by the Parties
Petitioner (Insurance Company):
- Argued that the Tribunal erred in assessing deceased’s notional monthly income at Rs. 15,000 per month in the absence of documentary evidence.
- Asserted this assessment was contrary to the minimum wage matrix applicable in Chhattisgarh at the relevant time.
- Sought modification of the award accordingly.
Respondent (Claimants):
- Submitted that the Tribunal undervalued the deceased’s notional income.
- Contended that mere Rs. 15,000 per month was on the lower side, considering the claim that the deceased earned Rs. 500 per day as a mason.
- Asserted that amounts under conventional heads were meager and sought enhancement and modification.
Factual Background
The case arose from a fatal motor vehicle accident on 29.03.2019, in which Rajeshwar died after being hit by a mini-truck driven in a rash and negligent manner. The claimants—comprising parents, wife, and children of the deceased—filed a compensation claim, asserting Rajeshwar earned Rs. 15,000 a month as a mason. The insurer disputed the claim but did not provide evidence against it. The Tribunal awarded Rs. 28,30,000 as compensation. Both the claimants (for enhancement) and the insurer (for reduction) appealed to the High Court.
Statutory Analysis
- The judgment involves interpretation of provisions under the Motor Vehicles Act relating to compensation in fatal accident cases.
- The Court applied the principles regarding determination of notional income, future prospects, deduction for personal and living expenses, and the use of appropriate multiplier based on the number of dependents and age of the deceased.
- The Court held that in the absence of documentary evidence to the contrary, pleadings of the claimants regarding income can be accepted and need not be disturbed on appeal.
Dissenting / Concurring Opinion Summary
No dissenting or concurring opinions were delivered; the judgment is authored and delivered by a single judge.
Procedural Innovations
No procedural innovations were introduced in the judgment.
Alert Indicators
- ✔ Precedent Followed – Existing law regarding appellate restraint in interfering with MACT factual findings reaffirmed.