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Deepak Singh Alias Deepak Chauhan v. Mukesh Kumar

Civil Appeal · 2025 INSC 179Decided 10 Feb 2025
C.A. No.-002255-002255 - 2025 (arising out of SLP(C) Diary No.236/2024)
Justice Sanjay Karol · Justice Manmohan

Background

In October 2012, Deepak Singh (also known as Deepak Chauhan) was riding pillion on a motorcycle when it collided with a speeding, rashly-driven Scorpio coming from the wrong side. His friend, who was driving, died on the spot, and Deepak suffered grievous injuries. The Motor Accident Claims Tribunal awarded him about Rs. 7.09 lakh in compensation, which the High Court later enhanced to about Rs. 23.9 lakh. Dissatisfied with how his notional income was calculated, Deepak appealed further to the Supreme Court.

Decision Breakdown

The dispute centred on what monthly "notional income" should be used to calculate compensation, since Deepak had no proven income at the time of the accident. The High Court had used minimum-wage rates for an unskilled worker. The Supreme Court disagreed, relying on its own precedent (Navjot Singh v. Harpreet Singh) involving a similarly-placed young claimant, and held that a flat minimum-wage figure understated the loss for a young claimant with future earning potential. Recomputing the award using a notional monthly income of Rs. 10,000 (with future prospects, permanent disability, medical expenses, and other standard heads factored in), the Court raised the total compensation to approximately Rs. 34.56 lakh with 7.5% annual interest from the date of filing the claim (excluding a 642-day delay period before the Supreme Court appeal was filed).

Lesson Learnt

When a young accident victim has no proven income, courts should not automatically peg compensation to bare minimum wages: a more realistic notional income, guided by precedent for similarly situated claimants, should be used so the compensation genuinely reflects the loss suffered.

Official source (sci.gov.in)View Judgment (PDF)

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