Summary
| Category | Data |
|---|---|
| Court | Supreme Court of India |
| Case Number | C.A. No.-014756-014756 – 2025 |
| Diary Number | 1108/2024 |
| Judge Name | HON’BLE MR. JUSTICE K. VINOD CHANDRAN |
| Bench |
HON’BLE MR. JUSTICE AHSANUDDIN AMANULLAH HON’BLE MR. JUSTICE K. VINOD CHANDRAN |
| Precedent Value | Binding authority |
| Overrules / Affirms | Affirms Reshma Kumari v. Madan Mohan (2013 SCC OnLine SC 284) |
| Type of Law | Motor Accident compensation |
| Questions of Law |
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| Ratio Decidendi | The Court held that in fatal accident claims involving minors, notional monthly income as per the Minimum Wages Act, 1948 for a Class B city (Rs.5,400) may be adopted with a 40% addition for future prospects. A multiplier of 15, as laid down in Reshma Kumari v. Madan Mohan, is to be applied; the 18‐fold multiplier in Baby Sakshi Greola applies to disability claims, not death cases. Half of the notional income is to be deducted for personal expenses. Heads such as loss of estate, filial consortium, medical expenses, funeral expenses and compensation for pain and suffering are to be separately awarded. |
| Judgments Relied Upon |
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| Logic / Jurisprudence / Authorities Relied Upon by the Court |
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| Facts as Summarised by the Court |
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Practical Impact
| Category | Impact |
|---|---|
| Binding On | All Motor Accident Claims Tribunals |
| Persuasive For | High Courts on similar motor accident compensation issues |
| Distinguishes | Baby Sakshi Greola v. Manzoor Ahmad Simon & Anr. (2024 INSC 963) |
| Follows | Reshma Kumari v. Madan Mohan (2013 SCC OnLine SC 284) |
What’s New / What Lawyers Should Note
- Supreme Court clarifies that notional income under the Minimum Wages Act, 1948 (Class B city rate of Rs.5,400) is appropriate for minor death claims.
- Confirms a uniform 40% addition for future prospects in fatality cases, regardless of the victim’s age.
- Distinguishes the 18-fold multiplier in disability cases (Baby Sakshi Greola) from the 15-fold multiplier for death claims (Reshma Kumari).
- Recognizes an award for pain and suffering where the victim survives post-accident for a period.
- Endorses award of loss of estate, filial consortium, medical and funeral expenses alongside dependency.
Summary of Legal Reasoning
- A 14‐year‐old’s death claim differs fundamentally from disability claims; therefore the 18-fold multiplier in Baby Sakshi Greola is inapplicable.
- Both parties agreed to adopt notional income under the Minimum Wages Act, 1948 for a Class B city (Rs.5,400).
- A 40% uplift for future prospects was applied to the notional income.
- A multiplier of 15, as per Reshma Kumari v. Madan Mohan, governs death claims.
- One-half of the notional income is deductible for the deceased’s personal use.
- Additional heads—loss of estate, filial consortium, medical expenses (Rs.50,000), funeral expenses (Rs.15,000) and pain and suffering (Rs.25,000)—were separately quantified.
Arguments by the Parties
Petitioner
- The High Court’s criteria for assessing dependency were grossly inadequate; evidence of peers’ earning capacity supported a higher multiplier.
- A multiplier of 18 should apply, as adopted in Baby Sakshi Greola.
Respondent (Insurance Company)
- No objection to adopting minimum wages as notional income.
- The multiplier must be confined to 15, consistent with Reshma Kumari v. Madan Mohan.
Factual Background
A 14-year-old boy proceeding to school with classmates was struck by a negligently driven truck; he succumbed to injuries the next day while two classmates died instantly. His parents’ claim before the Motor Accident Claims Tribunal resulted in an award of Rs.1,29,500; the High Court enhanced it to Rs.4,70,000. On appeal, the Supreme Court re-calculated compensation heads and enhanced the award to Rs.8,65,400.
Statutory Analysis
- Adopted notional monthly income under the Minimum Wages Act, 1948 for Class B cities.
- Applied the multiplier principle as understood under the Motor Vehicles Act jurisprudence, confirming 15-fold for death cases.
- Incorporated a 40% enhancement for future prospects, consistent with established practice.
Alert Indicators
- ✔ Precedent Followed – Reaffirms Reshma Kumari v. Madan Mohan
- 🔄 Conflicting Decisions – Distinguishes Baby Sakshi Greola v. Manzoor Ahmad Simon