Summary
| Category | Data |
|---|---|
| Court | Supreme Court of India |
| Case Number | C.A. No.-011425-011425 – 2025 |
| Diary Number | 993/2020 |
| Judge Name | HON’BLE MR. JUSTICE AHSANUDDIN AMANULLAH |
| Bench | HON’BLE MR. JUSTICE AHSANUDDIN AMANULLAH; HON’BLE MR. JUSTICE K. VINOD CHANDRAN |
| Precedent Value | Binding authority |
| Overrules / Affirms | Affirms |
| Type of Law | Motor accident compensation |
| Questions of Law |
|
| Ratio Decidendi | The High Court’s unexplained reduction of the tribunal’s assessed income cannot stand; where documentary proof is lacking but the deceased had professional qualifications and business interests, the Court may benchmark income against comparable standards (e.g., a coolie’s earnings with annual increments). The multiplier and future prospects must be applied in accordance with National Insurance Co. Ltd. v. Pranay Sethi, and standard heads of damage (loss of estate, funeral expenses, consortium) adhere to constitutional bench rulings. |
| Judgments Relied Upon |
|
| Logic / Jurisprudence / Authorities Relied Upon by the Court |
|
| Facts as Summarised by the Court | Four friends on a pilgrimage died in a collision caused by a negligent lorry driver; claimants sought compensation. The tribunal fixed the deceased’s income at ₹6,000/month; the High Court reduced it to ₹5,500 without citing material. |
Practical Impact
| Category | Impact |
|---|---|
| Binding On | All subordinate courts deciding motor accident claims |
| Persuasive For | High Courts considering quantum of compensation |
| Follows |
|
What’s New / What Lawyers Should Note
- Supreme Court will re-evaluate income estimates when a High Court reduces them without any material basis.
- Income benchmarking can rely on a coolie’s earnings with annual increments in absence of authenticated proof.
- Confirms application of multiplier and 25% future prospects as per Pranay Sethi in non-regular employment cases.
- Validates ₹15,000 each for loss of estate and funeral expenses and ₹40,000 per dependent for loss of consortium.
Summary of Legal Reasoning
- The Tribunal’s ₹6,000/month assessment was based on partial documentary proof; the High Court’s reduction to ₹5,500 lacked any reasoning or reference to materials.
- The Court noted that the deceased held a pharmacy diploma, ran a distributorship partnership, and was a bank director, justifying a higher income.
- Relying on Ramachandrappa, a coolie’s 2004 income of ₹4,500 with annual ₹500 increments yields ₹7,500 for 2010; this benchmark supports uplift.
- Considering qualifications and business interests, the Court assumed a ₹12,000/month income.
- Multiplier of 14 and 25% future prospects were applied per Pranay Sethi; 1/4th deduction for four dependants was appropriate.
- Constitutional bench precedents fixed ₹15,000 each for funeral and estate loss; consortium at ₹40,000 per dependant.
Arguments by the Parties
Petitioner (claimants):
- Deceased’s actual earning capacity was much higher due to multiple business interests and professional qualifications.
- High Court’s reduction lacked any factual or documentary basis and was arbitrary.
Respondent (Oriental Insurance Company):
- No authenticated proof of the deceased’s medical shop licence (cancelled before the accident), distributorship income or bank sitting fees.
- Monthly income claims were unsubstantiated and should not exceed tribunal’s estimate.
Factual Background
Four friends from Bijapur en route to Shirdi were killed when a goods lorry, driven rashly and negligently, collided with their car. Each group filed separate claim petitions; tribunals fixed the lead claimant’s deceased husband’s monthly income at ₹6,000 and awarded compensation. The High Court, without citing any material, reduced it to ₹5,500. Claimants appealed to enhance compensation under the Motor Vehicles Act regime.
Alert Indicators
- ✔ Precedent Followed