Addressing Notional Income, The Supreme Court Enhances Compensation For Motor Accident Victim.

The appeal in Deepak Singh Alias Deepak Chauhan Vs Mukesh Kumar & Ors arises from a motor vehicle accident on October 12, 2012, where Deepak Singh and his friend Bhagwan Singh were riding a motorcycle and collided with a Scorpio driven rashly from the wrong side. Bhagwan Singh died at the scene, and Deepak Singh sustained grievous injuries. Deepak Singh filed a claim petition on January 7, 2013, seeking compensation for his injuries.

The Supreme Court addressed an appeal by Deepak Singh, agrieved by the compensation awarded by the Motor Accident Claims Tribunal (MACT), the appeal was made before the High Court seeking the enhancment of the awarded compentsation. It is pertinent to mention here that MACT had initially awarded Rs. 7,09,303 with 7.5% interest, and the High Court enhanced the compensation to Rs. 23,90,719, keeping the interest rate the same.

The claimant-appellant further appealed to the Supreme Court, contesting the High Court's reliance on minimum wages to calculate compensation. The Supreme Court allowed the appeal, further enhancing the compensation based on a notional income of Rs. 10,000 per month, and awarded a total compensation of Rs. 34,56,110 with 7.5% interest from the date of filing the claim petition, excluding a delay period.

Reliance on Notional Income: The court referenced its order in Navjot Singh v. Harpreet Singh (Click to Download), noting that equating the notional income of a student to that of an unskilled worker is not appropriate.

Re-evaluation of Compensation: The court determined that a notional income of Rs. 10,000 per month should be considered for calculating compensation, leading to a recomputation of the compensation amount.

Interest on Awarded Amount: The court maintained an interest rate of 7.5% per annum on the awarded amount, calculated from the date of filing the claim petition, excluding a specific delay period.

Final Decision The Supreme Court allowed the appeal and enhanced the total compensation to Rs. 34,56,110, along with interest at 7.5% per annum from the date of filing the claim petition before the Tribunal, excluding the delay period in filing the appeal before the Supreme Court.

Coram: Justice Sanjay Karole and Justice Manmohan
Case: Deepak Singh Alias Deepak Chauhan Vs Mukesh Kumar & Ors
Judgment Date: 10-02-2025