The Chhattisgarh High Court has held that when there is no direct proof of income, the applicable minimum wages matrix for skilled workers must be adopted for determining the deceased’s income in motor accident compensation claims. This judgment enhances clarity on the statutory adoption of minimum wages in such contexts and is binding on all subordinate courts within Chhattisgarh.
Summary
| Category | Data |
|---|---|
| Case Name |
MAC/1340/2024 of SMT. RANJANBATI Vs SANTOSH TANDI CNR CGHC010222442024 |
| Date of Registration | 04-07-2024 |
| Decision Date | 15-10-2025 |
| Disposal Nature | PARTLY ALLOWED |
| Judgment Author | Hon’ble Shri Justice Rakesh Mohan Pandey |
| Court | High Court of Chhattisgarh at Bilaspur |
| Precedent Value | Binding on subordinate courts in Chhattisgarh |
| Type of Law | Motor Accident Compensation (Personal Injury Law) |
| Questions of Law | Whether minimum wage matrix should be applied for assessing income of deceased skilled workers in absence of direct proof of income. |
| Ratio Decidendi |
The Court held that, in the absence of direct proof of actual income, the minimum wage matrix applicable on the relevant date for the skill category of the deceased must be applied to determine income. The Tribunal erred in not adopting the higher amount stated in the minimum wage matrix for skilled workers, and compensation must be recalculated on this basis. Thus, the award was enhanced by considering the correct minimum wage. |
| Facts as Summarised by the Court |
The deceased, a 50-year-old mason, died from injuries arising out of a motor vehicle accident. The Claims Tribunal fixed his monthly income at Rs. 10,000, below the minimum wage for skilled labour applicable in April 2023, which was Rs. 11,390. The widow and sons sought enhancement, arguing for the minimum wage. |
Practical Impact
| Category | Impact |
|---|---|
| Binding On | All subordinate courts in Chhattisgarh |
| Persuasive For | Other High Courts and Tribunals in similar factual situations |
What’s New / What Lawyers Should Note
- Chhattisgarh High Court affirms that minimum wage matrix for skilled labour is to be adopted as the notional income where actual proof is absent.
- Lawyers should pay close attention to current government minimum wage notifications for accurate claim calculation.
- Awards below the notified minimum wage for skilled or semi-skilled victims are liable to be enhanced on appeal.
Summary of Legal Reasoning
- The Court noted the absence of direct proof of monthly income for the deceased mason.
- The Tribunal had assessed a notional income of Rs. 10,000, but the government minimum wage for skilled labour as of April 2023 was Rs. 11,390/month.
- The Court clarified that when assessing compensation in the absence of conclusive income evidence, the statutorily notified minimum wage must be adopted for the relevant skill category.
- On this basis, the monthly income was revised to Rs. 11,400 (rounded up from Rs. 11,390), and compensation recalculated for all heads, resulting in an enhanced total award.
Arguments by the Parties
Appellants/Claimants
- The deceased was a skilled mason, entitled to at least the minimum wage for skilled labour under government notifications as of April 2023.
- The Tribunal erred in awarding a lower notional income.
- The claimants (widow and sons) sought enhancement strictly as per minimum wages.
Respondents/Insurance Companies
- The claimants failed to prove actual income with documentary evidence.
- The Tribunal’s adoption of Rs. 10,000 as notional monthly income was proper.
- Opposed enhancement, seeking dismissal of the appeal.
Factual Background
The deceased, Sukhlal Netam, a 50-year-old mason, died following injuries sustained in a road accident on 12.04.2023 involving a Creta car. The Claims Tribunal awarded compensation based on a monthly income of Rs. 10,000. The claimants—his widow and two sons—appealed for enhancement, relying on the minimum wage for skilled workers applicable at the time.
Statutory Analysis
- The Court interpreted the relevance of government minimum wage notifications applicable for the skilled worker category (mason) in April 2023.
- It clarified application of the minimum wage matrix as binding for notional income assessment under the Motor Vehicles Act in absence of direct income proof.
Alert Indicators
- ✔ Precedent Followed – The Court affirmed and clarified the binding application of minimum wage notifications as the basis for notional income in compensation claims when actual proof is lacking.