Homemaker’s Services Cannot Be Undervalued: Punjab & Haryana High Court Enhances Motor Accident Compensation by Recognising Economic Value of Domestic Work Holds Homemaker’s Contribution Cannot Be Treated as Having No Pecuniary Value

Case Name: Bala v. Jitender Singh & Others

Date of Judgment: 10 July 2026

Citation: FAO-4483-2004

Bench: Hon’ble Mr. Justice Amarinder Singh Grewal

Held: The Punjab & Haryana High Court held that the contribution of a homemaker cannot be treated as having negligible or no pecuniary value while determining compensation under the Motor Vehicles Act. The Court ruled that the income of a homemaker should be assessed realistically by recognising her multifaceted contribution to the family, including household management and caregiving. Consequently, the Court enhanced the compensation payable to the injured claimant by reassessing her notional income, applying future prospects and the multiplier method.

Summary: The appeal arose from an award passed by the Motor Accident Claims Tribunal, Sonipat, granting ₹1,40,000 as compensation to the claimant who suffered grievous injuries, including pelvic fractures and 50% permanent disability, in a motor vehicle accident caused by the rash and negligent driving of the offending vehicle. Dissatisfied with the quantum awarded, the claimant sought enhancement, contending that the Tribunal had undervalued her income by treating her merely as a housewife and had failed to adequately compensate her for permanent disability, loss of earning capacity, pain and suffering, and other consequential losses.

The High Court observed that the Tribunal’s assessment ignored the settled legal position regarding the economic value of homemakers’ services. Referring to earlier decisions of the Punjab & Haryana High Court and the Supreme Court, including Lata Wadhwa, Pranay Sethi, Sarla Verma, and Arvind Kumar Pandey, the Court reiterated that a homemaker performs indispensable services extending beyond measurable economic parameters. Household management, caregiving, emotional support, and maintaining family stability possess real economic value and must be recognised while computing compensation under the Motor Vehicles Act.

Taking judicial notice of the prevailing minimum wages of skilled workers in Haryana in 2002, the Court reassessed the claimant’s monthly income at ₹2,310 and added 40% towards future prospects in accordance with Pranay Sethi. Considering the claimant’s 50% permanent disability, the Court applied the multiplier of 15 as prescribed in Sarla Verma and recalculated the loss of future earning capacity. The Court further enhanced compensation under the heads of pain and suffering and loss of amenities while maintaining the amounts awarded towards medical expenses and attendant charges.

The Court emphasised that just compensation requires courts to recognise the genuine economic contribution of homemakers and avoid outdated assumptions that domestic work carries little or no monetary value. Such recognition is essential to ensure fair and equitable compensation in motor accident claims.

Decision: The appeal was partly allowed. The compensation payable to the claimant was enhanced from ₹1,40,000 to ₹3,71,060, with the enhanced amount carrying interest at 7.5% per annum from the date of filing of the claim petition until realization.