The Chhattisgarh High Court clarifies that, where documentary proof is absent, the statutory minimum wage notification must guide income assessment of deceased victims in motor accident claims. The judgment affirms and applies Supreme Court decisions (Pranay Sethi, Sarla Verma, Magma General Insurance), establishing practical precedent for enhanced compensation calculation across tribunals.
Summary
| Category | Data |
|---|---|
| Case Name | MAC/125/2022 of Mangli Bai Chandra Vs Sohan Singh |
| CNR | CGHC010024242022 |
| Date of Registration | 20-01-2022 |
| Decision Date | 27-10-2025 |
| Disposal Nature | DISPOSED OFF |
| Judgment Author | Hon’ble Shri Justice Sanjay K. Agrawal |
| Court | High Court of Chhattisgarh |
| Bench | Single Bench |
| Precedent Value | Binding on tribunals and subordinate courts within Chhattisgarh; persuasive elsewhere |
| Overrules / Affirms | Affirms and applies Supreme Court precedents (Pranay Sethi, Sarla Verma, Magma General Insurance) |
| Type of Law | Motor Accident Compensation, Civil Law |
| Questions of Law |
|
| Ratio Decidendi |
The Court held that, in absence of clinching evidence of actual income, the minimum wage notification issued by the relevant State authority must be applied to assess the deceased’s monthly income for the purpose of compensation under Section 166 of the Motor Vehicles Act. It further reaffirmed and applied the methodology directed in Pranay Sethi (future prospects, deduction for personal expenses), Sarla Verma (multipliers), and Magma General Insurance (categories of consortium), ensuring that calculation aligns with binding Supreme Court precedent and up-to-date statutory wage rates. Enhancement is warranted if the tribunal adopts an income below statutory minimum without justification. |
| Judgments Relied Upon |
|
| Logic / Jurisprudence / Authorities Relied Upon by the Court |
|
| Facts as Summarised by the Court |
The deceased, aged 52, was the sole breadwinner; his dependents sought compensation for his death in a motor accident. The tribunal assessed income lower than current minimum wage. This was challenged on grounds of improper computation and disregard of statutory wage notification. No direct documentary evidence of income was produced. |
Practical Impact
| Category | Impact |
|---|---|
| Binding On | Tribunals and subordinate courts in Chhattisgarh |
| Persuasive For | Other High Courts and across India in similar claims |
| Follows |
|
What’s New / What Lawyers Should Note
- The statutory minimum wage notification is to be strictly followed for computation of income where no documentary evidence is produced by the dependents of the deceased.
- Calculation of compensation must comply with the principles laid out in Pranay Sethi (regarding future prospects and personal expense deduction), Sarla Verma (application of multiplier), and Magma General Insurance (consortium heads for spouse, children, and parents).
- Any compensation awarded below the statutory minimum wage is liable to be enhanced if challenged.
- Advocates must cite minimum wage notifications and demand inclusion of all consortium heads as per recent Supreme Court judgments for full compensation.
Summary of Legal Reasoning
- The Court found the tribunal erred in adopting a notional monthly income below the statutory minimum prescribed by the Chhattisgarh Minimum Wages Notification; in absence of direct documentary proof, the minimum wage becomes the default standard.
- Relied on Supreme Court precedents—Pranay Sethi for determination of future prospects and structuring “just compensation,” Sarla Verma for applying the correct multiplier based on age, and Magma General Insurance for liberal inclusion of heads such as spousal, parental, and filial consortium.
- The computation method was laid out in a comparative table, demonstrating direct application of minimum wage, future prospects, deduction for personal expenses, and addition of separate consortium and statutory heads.
- The Court enhanced the compensation accordingly and specified interest terms, directing prompt payment of differential amounts.
Arguments by the Parties
Petitioner (Appellants):
- The tribunal awarded a meager compensation by improperly fixing the deceased’s income at Rs. 6,000/- per month.
- The correct income should be Rs. 9,250/- per month as per the Minimum Wages Notification.
- Sought enhancement of compensation in compliance with Supreme Court guidelines.
Respondent (Insurance Company):
- The appellants failed to prove the exact income via admissible evidence.
- The tribunal was justified in adopting a notional income.
- The awarded compensation is just and calls for no interference.
Factual Background
The deceased, Neelkanth Chandra, aged 52, was the sole breadwinner for the family and died in a road accident involving a vehicle owned by respondent Sohan Singh and insured by United India Insurance Co. Ltd. The dependents filed a claim under Section 166 of the Motor Vehicles Act for Rs. 46,47,500/-. The Tribunal awarded Rs. 7,30,400/- considering Rs. 6,000/- monthly income, which the claimants challenged, arguing the minimum wage norm should apply. No documentary proof of income was filed; assessment rested on statutory notification rates.
Statutory Analysis
- Motor Vehicles Act, 1988, Section 166 & Section 173: Application for and appeal against compensation awards.
- Chhattisgarh Minimum Wages Notification: Relied upon for ascertaining notional income in absence of documentary evidence.
- The Court did not “read down” or “read in” any statutory language, but followed a direct and literal application of the minimum wage standards.
- Supreme Court guidelines on calculation heads—future prospects, deduction for personal expenses, multiplier (Pranay Sethi, Sarla Verma), consortium (Magma General Insurance).
Alert Indicators
- ✔ Precedent Followed – Existing law and Supreme Court precedent strictly reaffirmed and applied.