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Mohinder Kaur (D) Through L.R. v. Brij Lal Arora & Ors.

Civil Appeal · 2026 INSC 477Decided 12 May 2026
C.A. No.-007459-007459 - 2026 (arising from SLP (Civil) No. 580 of 2020)
Justice S.V.N. Bhatti · Justice Vijay Bishnoi

Background

In 2000, a 22-year-old mechanical engineering student, Karan Pal Singh, died after a truck struck his motorcycle. His mother filed a motor accident compensation claim. The Motor Accident Claims Tribunal awarded her Rs. 2,23,000 in 2003, assessing the deceased's notional income at just Rs. 3,000/month. On appeal, the Punjab and Haryana High Court raised this to Rs. 13,44,000 in 2018, assessing income at Rs. 6,000/month but still declining to add "future prospects" or conventional-head amounts at levels the appellant sought. The claimant (later substituted by her daughter as legal representative after her death) appealed to the Supreme Court seeking further enhancement.

Decision Breakdown

The Supreme Court held that both the Tribunal's and the High Court's income assessments were far too low for a meritorious final-year engineering student who also held a diploma in Plastic Engineering and an AutoCAD certification, citing its own precedents (Navjot Singh, Arvind Kumar Mishra, Basanti Devi) where notional incomes of engineering students were assessed much higher. It fixed the deceased's notional monthly income at Rs. 12,000, and held the High Court was wrong to deny "future prospects" merely because the income was notional, following Pranay Sethi, it added 40% future prospects, deducted 50% for personal expenses since the deceased was unmarried, and applied the multiplier of 18. It also revised the conventional heads (loss of estate, filial consortium, funeral expenses) upward per the Pranay Sethi/Magma General Insurance scale, and corrected the motorcycle-damage award to match the actual surveyor's valuation. Total compensation was raised to Rs. 19,25,070, with 7.5% annual interest, payable within eight weeks.

Lesson Learnt

In motor accident death claims involving young students with no established income, courts should assess "notional income" realistically based on the deceased's demonstrated academic merit and qualifications rather than treating them as unskilled workers, and "future prospects" must be added to notional income even when that income figure is itself an estimate. It cannot be denied solely because the income wasn't an actual, proven salary.

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

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