Punjab & Haryana High Court Enhances Compensation to ₹9.28 Lakh for Death of Homemaker in Road Accident, Recognizes Economic Value of Domestic Work
Case Name: Ranbir Singh and Another v. Gurdeep Singh and Another
Date of Judgment: October 9, 2025
Citation: FAO-7840-2017
Bench: Hon’ble Mrs. Justice Sudeépti Sharma
Held: The Punjab & Haryana High Court enhanced compensation from ₹5.35 lakh to ₹9.28 lakh in a motor accident claim involving the death of a 60-year-old homemaker, recognizing that domestic work holds measurable economic value. Justice Sudeépti Sharma ruled that the Tribunal had erred by undervaluing the deceased’s contribution to the household and by failing to consider future prospects, proper deductions, and compensation under conventional heads. The Court emphasized that while homemakers’ services are unpaid, their role in maintaining household stability and providing care must be equitably monetized for the purpose of awarding just compensation.
Summary: The appeal arose from an award dated July 11, 2017, passed by the Motor Accident Claims Tribunal, Sangrur, granting ₹5.35 lakh with 7% interest to the claimants on account of Ranjit Kaur’s death in a motor vehicle accident on July 7, 2016. The appellants sought enhancement of the amount, contending that the Tribunal failed to apply the principles laid down in Sarla Verma v. DTC (2009) 6 SCC 121 and National Insurance Co. Ltd. v. Pranay Sethi (2017) 16 SCC 680 regarding multiplier, future prospects, and deductions.
Justice Sharma observed that although the deceased was a graduate and trained teacher who provided tuition, the Tribunal had treated her only as a homemaker and fixed her monthly income at ₹5,000. The Court referred to its earlier judgment in Jasbir Singh v. Surjit Singh (FAO-1292-2006), holding that the notional income of a housewife should be determined at least at ₹9,000 per month. Considering inflation, the Court assessed her income at ₹10,000 per month with a 10% addition for future prospects.
The Court further applied a 1/3rd deduction for personal expenses and a multiplier of 9 based on the deceased’s age (60 years as per post-mortem report). It also awarded compensation for loss of estate, funeral expenses, and consortium in accordance with Pranay Sethi and Magma General Insurance Co. Ltd. v. Nanu Ram (2018) 18 SCC 130, granting ₹48,400 each for spousal and parental consortium.
Decision: Allowing the appeal, the High Court enhanced the total compensation to ₹9,28,264 from ₹5,35,000, with 9% interest per annum from the date of claim petition till realization. The Insurance Company was directed to deposit the enhanced amount within two months, with liberty to recover it from the owner of the offending vehicle as per the Tribunal’s award.