Claimants are entitled to compensation based on the statutory minimum wage rate prevailing at the time of the accident, even if the Tribunal assessed a lower figure; the Chhattisgarh High Court aligns its determination with Supreme Court precedents (Pranay Sethi, Sarla Verma, Magma General Insurance) and affirms calculation methodology for future claims. This judgment sets a clear, binding standard for all subordinate courts in Chhattisgarh on motor accident compensation under the Motor Vehicles Act.
Summary
| Category | Data |
|---|---|
| Case Name |
MAC/52/2023 of SMT. ARTI Vs RUPNATH SINGH POYAM CNR CGHC010009762023 |
| Date of Registration | 09-01-2023 |
| Decision Date | 30-10-2025 |
| Disposal Nature | ALLOWED |
| Judgment Author | HON’BLE SHRI JUSTICE SANJAY K. AGRAWAL |
| Court | High Court of Chhattisgarh |
| Bench | Single Bench |
| Precedent Value | Binding on subordinate courts in Chhattisgarh |
| Type of Law | Motor Vehicles Act – Compensation |
| Questions of Law | Whether the minimum wage as per notification should be adopted over Tribunal’s assessment for computation of compensation for deceased in motor accident cases. |
| Ratio Decidendi |
The High Court held that the monthly income of the deceased in a motor accident claim must be determined on the basis of minimum wage notifications prevailing at the time of incident. The Tribunal’s lower assessment was set aside and compensation was recalculated accordingly. This is consistent with the methodology set forth by Supreme Court judgments in Pranay Sethi, Sarla Verma, and Magma General Insurance, which form the legal benchmark for such matters. The Court affirmed the obligation to add future prospects, apply the correct multiplier, and allocate conventional heads as per binding precedents. |
| Judgments Relied Upon |
|
| Logic / Jurisprudence / Authorities Relied Upon by the Court | Income assessment must be based on prevailing minimum wages; compensation must be calculated as per Supreme Court formulas, with proper allowance for future prospects, personal deduction, multiplier, funeral expenses, loss of estate, consortium, and actual bills. |
| Facts as Summarised by the Court | Deceased, aged 41, worked as Rajmistri. His monthly income was assessed lower than notified minimum wage by Tribunal. Claimants appealed for enhancement. Court recalculated compensation based on correct statutory wage and allowances. |
Practical Impact
| Category | Impact |
|---|---|
| Binding On | All subordinate courts in Chhattisgarh regarding compensation computation under the Motor Vehicles Act. |
| Follows | Supreme Court: Pranay Sethi (2017), Sarla Verma (2009), Magma General Insurance (2018); methodology and heads for accident compensation. |
What’s New / What Lawyers Should Note
- Clarifies that statutory minimum wage rates prevailing at the time of accident must be used in assessing the deceased’s income for motor accident compensation.
- Reiterates strict adherence to Supreme Court guidelines for heads of compensation, future prospects, deduction, multiplier, and other conventional sums.
- Establishes calculation method as binding precedent for all accident claim matters in the state.
- Lawyers may cite this for enhancement claims or to challenge arbitrary/lower income assessments by subordinate tribunals.
Summary of Legal Reasoning
- The Court scrutinised the Tribunal’s method of income assessment and found it inconsistent with the minimum wage notification applicable at the relevant time.
- The High Court adopted the statutory minimum wage, increasing the base income considered in computation.
- Applying Supreme Court dicta from Pranay Sethi, Sarla Verma, and Magma General Insurance, the Court allowed for future prospects, correct personal deduction (1/3), and the established multiplier (14).
- Conventional heads (funeral expenses, loss of estate, consortium) were updated as per the prescribed formulas.
- Final compensation was thus recalculated, and the claimants’ entitlement enhanced accordingly.
Arguments by the Parties
Petitioner
- Tribunal erred by using a monthly income lower than statutory minimum wage.
- Sought re-calculation as per minimum wage notification for the relevant period for fair and just compensation.
Respondent No. 3 (United India Insurance Company)
- Supported the Tribunal’s award.
- Argued compensation already just and proper, no interference warranted.
Factual Background
- The deceased (aged 41), a Rajmistri by profession, died in a motor vehicle accident.
- The Claims Tribunal awarded compensation by assessing monthly income at Rs. 9,510, lower than the applicable minimum wage.
- Claimants appealed under Section 173 of the Motor Vehicles Act, seeking enhancement to align with statutory wage rates.
- The dispute turned on the correct methodology for computing compensation.
Statutory Analysis
- Section 173, Motor Vehicles Act: Right to appeal against Tribunal award.
- The Court discussed the application of minimum wage notifications in assessing deceased’s income for compensation.
- Followed the Supreme Court’s prescribed heads for calculating just compensation as required under the Act.
Alert Indicators
- ✔ Precedent Followed – Judgment applies and follows binding Supreme Court precedents (Pranay Sethi, Sarla Verma, Magma General Insurance) regarding computation of compensation.