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Karuna Parmar v. Prakash Sinha and Others

Civil Appeal · 2025 INSC 1244Decided 11 Feb 2025
C.A. No.-002317-002317 - 2025 (arising out of SLP (C) No.6428/2023, with a connected appeal from SLP (C) No.6314/2023 - Ramchand Singh Parmar v. Prakash Sinha and Others)
Justice Sanjay Karol · Justice Manmohan

Background

In March 2014, Karuna Parmar, her husband Ramchand Singh Parmar, and their six-year-old daughter were travelling by car when a truck driven rashly and negligently by the respondent struck their vehicle. The parents suffered serious injuries and their daughter died. The Motor Accidents Claims Tribunal awarded relatively modest compensation to both parents and for the deceased child, and the Madhya Pradesh High Court only partly enhanced the mother's award, leaving the father's claim and the child's compensation largely unchanged, prompting both parents to appeal to the Supreme Court.

Decision Breakdown

The Supreme Court substantially increased the compensation across all three claims. For the mother, it held her pre-accident income as a professor (Rs. 16,000/month, which she had held until two years before the accident) should be factored into her earning capacity rather than ignored, raising her monthly income basis to Rs. 26,000, and it also held that medical expense awards should not be mechanically capped at the bills produced, awarding the higher amount she claimed following its earlier ruling in Kajal v. Jagdish Chand. For the deceased child, the Court rejected the Tribunal's arbitrary notional income and instead applied the principle from Baby Sakshi Greola v. Manzoor Ahmad Simon that a minor's income should be based on the prevailing minimum wage for a skilled worker, substantially raising the compensation for loss of estate, funeral expenses, and parental consortium. The final amounts increased sharply across the board - e.g., the mother's compensation rose from Rs. 3.84 lakhs (Tribunal) and Rs. 5.41 lakhs (High Court) to Rs. 9.09 lakhs, and the child's award rose from Rs. 5.30 lakhs to Rs. 11.44 lakhs.

Lesson Learnt

In motor accident compensation cases, courts should not mechanically rely on a claimant's income at the exact moment of the accident or cap medical costs strictly to bills produced - they must account for genuine earning capacity, minimum-wage benchmarks for minors, and realistic future prospects to arrive at just compensation.

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

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