Rani @ Raj Kumari And Others Vs Kamlakat Gupta And Others (Supreme Court of India)
Salary + Farming Income Recognised: Supreme Court Corrects HC’s “Undervalued Income” Assessment- SC Quadruples Consortium: 40,000 to Each of 7 Claimants — Compensation Jumps to 20.55 Lakhs
Supreme Court examined enhancement of compensation for death of 33-year-old Sobran Singh in a motor accident. Tribunal had awarded Rs.7,28,500 while High Court enhanced it to Rs.9,20,500 applying 40% future prospects but reduced multiplier from 17 to 15. SC noted that salary certificate & Khatauni documents issued by the Stone Crusher Company sufficiently established monthly income of Rs.6,000. SC further held that farming income could not be ignored & reasonably added Rs.2,000 per month, fixing income at Rs.8,000. Applying Pranay Sethi, SC adopted multiplier 16 (age 33–35 years) & deduction of 1/5th considering seven dependants. Annual income after future prospects was placed at Rs.60,480, resulting in loss of dependency at Rs.17,20,320. Tribunal & HC had significantly undervalued consortium; SC granted Rs.40,000 each towards spousal, filial & parental consortium totalling Rs.2,80,000. Treatment expenses enhanced to Rs.25,000 & funeral expenses to Rs.15,000. Total compensation fixed at Rs.20,55,320 with 7% interest from date of claim, directing insurer to deposit balance enhancement of Rs.11,34,820 within eight weeks. Appeal allowed with modification.
