Punjab & Haryana High Court Enhances Compensation in Motor Accident Death Case; Corrects Tribunal’s Deductions and Applies Pranay Sethi Formula

Case Name: Shashi Sapra and Others vs. Nafe Singh and Others
Date of Judgment: 13 November 2025
Citation: FAO-95-2003
Bench: Hon’ble Mr. Justice Virinder Aggarwal

Held: The Punjab and Haryana High Court allowed the appeal seeking enhancement of compensation and held that the Motor Accident Claims Tribunal erred in assessing the income of the deceased, deducting one-third personal expenses, and excluding addition towards future prospects. The Court also held that the deduction of the amount received under the Group Personal Accident Scheme was impermissible in law. Applying the principles laid down in Pranay Sethi, Sarla Verma and later reaffirmed in Magma General Insurance Co. Ltd., the Court reassessed the compensation and enhanced it to ₹26,47,000/- with interest at 7% per annum.

Summary: The appeal arose from an accident in which Surender Kumar Sapra, employed with Engineers India Limited, died after the jeep in which he was travelling collided head-on with a tractor. The Tribunal had held both drivers equally negligent and awarded ₹13,72,000/- in compensation after deducting a sum received under the Group Personal Accident Scheme. The appellants sought enhancement on the grounds that the Tribunal undervalued the deceased’s income, failed to add future prospects, applied an incorrect deduction for personal expenses, and wrongly deducted service-related accident benefits. The High Court examined the deceased’s salary certificate, employment status, and dependency structure and held that being a government employee, 30% addition toward future prospects was mandatory. The Court also held that since there were four dependants, only one-fourth deduction was permissible.

Decision: The High Court reassessed the compensation based on the correct multiplier, proper deductions, future prospects, and conventional heads including spousal, parental and filial consortium, loss of estate and funeral expenses. The Court restored the amount deducted under the Group Personal Accident Scheme, holding that such benefits cannot be adjusted against statutory compensation payable under the Motor Vehicles Act. The compensation was enhanced from ₹13,72,000/- to ₹26,47,000/-, to carry interest at the rate of 7% per annum from the date of filing of the claim petition until realization. The liability was fixed jointly and severally on the respondents on a 50:50 basis due to composite negligence. The appeal was allowed to the extent of modification, and pending applications were disposed of.