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M.H. Uma Maheshwari & Ors. v. United India Insurance Co. Ltd. & Anr.

Civil Appeal · 2020 INSC 424Decided 12 Jun 2020
Civil Appeal No. 2558 of 2020
Justice N.V. Ramana · Justice R. Subhash Reddy · Justice Surya Kant

Background

S.T. Devaraju, the Commissioner of Raichur City Municipal Corporation, died after the car he was travelling in met with an accident. His widow and two children sought compensation, claiming he earned Rs. 55,000/month. The Tribunal awarded them about Rs. 65.6 lakh, applying a 30% addition for future prospects. The Karnataka High Court reduced this to about Rs. 57.8 lakh, cutting the future-prospects addition to 15% on the reasoning that the deceased was just over 50 years old, and also trimming the amount awarded for loss of love and affection.

Decision Breakdown

The Supreme Court held that the High Court had made an internal contradiction: it kept the same 13-year "multiplier" (appropriate for someone in the 40-50 age bracket) while simultaneously treating him as being in an older bracket to justify cutting future prospects to only 15%. Since the deceased's age squarely placed him in the 40-50 group under the Constitution Bench's guidelines in Pranay Sethi, the 30% future-prospects addition originally awarded by the Tribunal was correct and should not have been reduced. The Court restored the Tribunal's original, higher award in full.

Lesson Learnt

When courts use age-based formulas (like the "multiplier" and "future prospects" percentage) to calculate compensation, those formulas must be applied consistently with the same age bracket: a court cannot pick and choose different age assumptions to justify a lower final figure.

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

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