Punjab & Haryana High Court Enhances Compensation to ₹15.97 Lakh in Fatal Road Accident; Increases Future Prospects and Conventional Heads
Case Name: Krishna Devi & Others v. Satbir & Another
Date of Judgment: October 31, 2025
Citation: FAO-4050-2010
Bench: Hon’ble Mrs. Justice Sudeepti Sharma
Held: The Punjab & Haryana High Court enhanced the compensation payable to the family of deceased Anand Kumar from ₹7.15 lakh to ₹15.97 lakh with 9% annual interest, holding that the Motor Accident Claims Tribunal (MACT), Sonepat, had erred in excluding allowances, not applying future prospects, and using an incorrect multiplier. Justice Sudeepti Sharma ruled that house rent allowance (HRA), conveyance, and provident fund must be included in income computation, following Meenakshi v. Oriental Insurance Co. Ltd. (2024 INSC 583), and that future prospects and consortium must be added as per Pranay Sethi (2017) 16 SCC 680 and Magma General Insurance Co. Ltd. v. Nanu Ram (2018) 18 SCC 130.
Summary: Anand Kumar, aged 40, died in a 2008 road accident. The Tribunal had awarded ₹7.15 lakh with 7.5% interest. The claimants sought enhancement, arguing that the Tribunal ignored allowances, applied an incorrect multiplier of 13 instead of 15, and failed to add future prospects. The insurer opposed enhancement, claiming the award was just and proper.
The High Court reaffirmed that the income should include allowances and perquisites and that 30% must be added for future prospects. It relied on Sarla Verma v. DTC (2009) 6 SCC 121 for determining the multiplier based on age and on Sunita v. Vinod Singh (2025 INSC 366) for accepting age as per the post-mortem report. The Court also clarified that filial and spousal consortium must be quantified as ₹48,400 per head (after applying a 10% increase) and that the MACT had erred in not awarding compensation for “loss of estate.”
Decision: The High Court allowed the appeal, enhancing the total compensation to ₹15.97 lakh with 9% annual interest from the date of claim filing till realization. Justice Sudeepti Sharma held that the Tribunal had failed to account for allowances, future prospects, and updated conventional heads as per Pranay Sethi and Magma. The Court therefore reassessed the income, applied the correct multiplier of 15, and included all relevant heads such as loss of dependency, loss of consortium, funeral expenses, and loss of estate. The Insurance Company was directed to deposit the enhanced compensation with interest within two months for disbursement through the MACT in accordance with law.