Bhogireddi Varalakshmi & Ors. v. Mani Muthupandi & Ors.
Background
The claimants (widow and children of a 52-year-old man killed in a motor accident) were awarded compensation by the Motor Accident Claims Tribunal using a low multiplier of 6.31 and no addition for future prospects, and the High Court only partially improved this. On an earlier date in March 2017, the Supreme Court had already enhanced the multiplier to 11 and the consortium/loss-of-care amounts in line with its precedents in Sarla Verma and Rajesh v. Rajbir Singh, but had left the specific question of a "future prospects" addition for someone who died past age 50 pending, because conflicting Supreme Court decisions on that point had been referred to a larger Constitution Bench.
Decision Breakdown
By the time this final order was passed, the Constitution Bench had already resolved the conflict in National Insurance Company Ltd. v. Pranay Sethi (decided 31 October 2017), settling that claimants are entitled to a 15% addition for future prospects. Applying that newly settled law, the Supreme Court held the claimants were entitled to the 15% future-prospects enhancement on top of what had already been ordered in March 2017, and disposed of the appeal finally with no further issues left open.
Lesson Learnt
Motor accident compensation calculations (multiplier, consortium, and future-prospects additions) follow specific formulas laid down by the Supreme Court, and these formulas can themselves evolve through larger Constitution Bench rulings: claimants with pending matters can benefit from later, more claimant-favourable precedents even if their case had already been partly decided earlier.