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Prabhavathi v. The Managing Director, Bangalore Metropolitan Transport Corporation

Civil Appeal · 2025 INSC 293Decided 28 Feb 2025
C.A. No.-003465-003466 - 2025 (arising out of SLP(C) Nos.21450-21451/2023)
Justice Sanjay Karol · Justice Prashant Kumar Mishra

Background

A 38-year-old man, the sole earning member of his family, died after his motorcycle was hit by a BMTC bus being driven rashly and negligently. The Motor Accident Claims Tribunal awarded his dependents about Rs. 76 lakh in compensation, finding the bus driver fully responsible. On appeal, the Karnataka High Court reduced the driver's share of blame to 75%, holding the deceased 25% responsible for contributory negligence, while also lowering his assessed monthly income and awarding roughly Rs. 77.5 lakh. The deceased's family appealed to the Supreme Court, challenging both the finding of contributory negligence and the reduced income figure.

Decision Breakdown

The Supreme Court held that the High Court had no sufficient evidence to conclude the deceased shared any blame for the accident: merely alleging that both vehicles were travelling at high speed, without corroborating evidence, was not enough to fix contributory negligence under settled precedent. The Court also restored the higher, correctly documented monthly income figure (based on the deceased's actual pay slip) that the High Court had wrongly lowered. Recalculating compensation using the standard multiplier method (including future prospects and deductions for personal expenses), the Court raised the total award to about Rs. 1.2 crore, significantly higher than both the Tribunal's and the High Court's figures.

Lesson Learnt

In motor accident compensation cases, courts require actual evidence, not assumptions, before reducing a victim's compensation on grounds of shared fault, and compensation should be calculated based on documented income (like pay slips) rather than arbitrarily lowered estimates.

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

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