Punjab & Haryana High Court Enhances Compensation to ₹20.85 Lakh for 30-Year-Old Mechanic’s Death, Recognizes Educational Prospects in Income Assessment
Case Name: Parkash Devi and Others v. Naz-Bul Khan and Others
Date of Judgment: October 9, 2025
Citation: FAO-2985-2015
Bench: Hon’ble Mrs. Justice Sudeépti Sharma
Held: The Punjab & Haryana High Court enhanced the compensation awarded to the claimants from ₹9.38 lakh to ₹20.85 lakh, holding that the Motor Accident Claims Tribunal erred in assessing the deceased’s income based solely on minimum wages and in failing to account for his educational qualifications and potential future earnings. Justice Sudeépti Sharma ruled that for a young diploma student and working mechanic, minimum wage assessment was unrealistic and contrary to the principles laid down in Sharad Singh v. H.D. Narang (2025 INSC 1164). The Court also modified deductions, added 40% towards future prospects, and awarded compensation under conventional heads as per Pranay Sethi and Magma General Insurance Co. Ltd. v. Nanu Ram.
Summary: The appeal arose from a Motor Accident Claims Tribunal award dated November 18, 2014, granting ₹9.38 lakh compensation with 7.5% interest for the death of Kartik, who died in a road accident on April 4, 2013. The claimants sought enhancement, arguing that the deceased’s income as a skilled mechanic and diploma student was undervalued.
Justice Sharma referred to Sarla Verma v. DTC (2009) 6 SCC 121, National Insurance Co. Ltd. v. Pranay Sethi (2017) 16 SCC 680, and Magma General Insurance Co. Ltd. v. Nanu Ram (2018) 18 SCC 130*, reiterating that income assessment must reflect the deceased’s education, age, and potential, not mere minimum wages. The Court observed that the Tribunal had incorrectly deducted 50% for personal expenses despite there being three dependents (parents and an unmarried sister), and instead applied a 1/3rd deduction.
The Court assessed Kartik’s monthly income at ₹10,000 with a 40% addition for future prospects, applying a multiplier of 17 as per his age (30 years). Compensation for loss of estate and funeral expenses was enhanced to ₹18,150 each, while ₹1,45,200 was awarded for filial consortium to three dependents. The total compensation thus came to ₹20,85,432, resulting in an enhancement of ₹11,47,432 over the Tribunal’s award.
Decision: The High Court allowed the appeal, directing the Insurance Company to deposit the enhanced compensation with 9% annual interest within two months. The Tribunal was instructed to disburse the amount to the claimants in accordance with the original apportionment ratio.