Punjab & Haryana High Court Dismisses Claimants’ Appeal for Enhancement in Motor Accident Compensation; Says Issue Already Settled in Insurer’s Connected Case
Case Name: Neelam Rani & Another v. Kuldeep Singh & Others
Date of Judgment: October 31, 2025
Citation: FAO-2129-2016
Bench: Hon’ble Mrs. Justice Sudeepti Sharma
Held: The Punjab & Haryana High Court dismissed an appeal filed by the claimants seeking enhancement of compensation in a motor accident case, holding that the matter stood settled in a connected appeal (Magma HDI General Insurance Co. Ltd. v. Neelam Rani & Others, FAO-8656-2015) decided the same day. Justice Sudeepti Sharma observed that all questions regarding quantum, future prospects, and conventional heads had already been adjudicated in the insurer’s appeal and therefore required no separate determination.
Summary: The appeal arose from an award dated November 4, 2015, passed by the Motor Accident Claims Tribunal, Rohtak, granting ₹57,70,000 along with 7.5% annual interest to the claimants for the death of Kuldeep Singh in a road accident on June 27, 2012. The claimants contended that the Tribunal undervalued the income, multiplier, and conventional heads and sought enhancement based on the Supreme Court rulings in Sarla Verma v. DTC (2009) 6 SCC 121 and National Insurance Co. Ltd. v. Pranay Sethi (2017) 16 SCC 680.
The Court reviewed the settled legal principles governing compensation computation — deduction for personal expenses, selection of multiplier, and addition of future prospects — citing Sarla Verma, Pranay Sethi, and Magma General Insurance Co. Ltd. v. Nanu Ram (2018 18 SCC 130) on filial and spousal consortium. However, noting that the connected insurer’s appeal (FAO-8656-2015) had already been decided on the same date comprehensively covering these issues, the Court held that the present appeal did not survive for adjudication.
Decision: The High Court dismissed the appeal as infructuous, reiterating that the compensation awarded by the Tribunal, as modified in the insurer’s connected appeal, shall prevail. Pending applications were also disposed of.