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Sunita v. Vinod Singh

Civil Appeal · 2025 INSC 366Decided 19 Mar 2025
C.A. No.-004021-004021 - 2025 (arising from SLP (C) No.1114 of 2019)
Justice Sudhanshu Dhulia · Justice Ahsanuddin Amanullah

Background

On 07.02.2003, Smt. Tarawati was struck and killed by a truck while walking to a bus stand in Haryana. Her family sought Rs. 15 lakh in compensation before the Motor Accident Claims Tribunal (MACT), which awarded Rs. 4,31,680, later enhanced by the Punjab & Haryana High Court to Rs. 5,96,761 with 7.5% interest. The family appealed to the Supreme Court, arguing the lower courts had understated the deceased's age, income (which included family pension and notional homemaker wages), and had failed to apply settled compensation formulas properly.

Decision Breakdown

The Supreme Court held that the deceased's age (45 years, per the post-mortem report) and monthly income (family pension of about Rs. 5,137 plus notional homemaker wages, rounded to Rs. 7,000) had been undercounted, and recalculated compensation using the multiplier method from Sarla Verma v. Delhi Transport Corporation and the standardised heads from National Insurance Co. v. Pranay Sethi. It added 25% for loss of future prospects (relying on Rajendra Singh v. National Insurance Co.), corrected the personal-expense deduction to one-fourth as required by precedent, and increased amounts for funeral expenses and loss of love and affection/consortium (extended to all dependents per Magma General Insurance v. Nanu Ram). Total compensation was raised to Rs. 13,82,500, with 7.5% interest per annum from the date of filing until realisation, and the High Court's order was set aside.

Lesson Learnt

Compensation for the death of a homemaker must properly value her non-monetary domestic contribution alongside any actual income like pension, and courts must apply the full standardised formula (multiplier, future prospects, consortium for all dependents, correct personal-expense deduction) rather than an incomplete calculation, since motor accident law is meant to secure "just compensation," not a token sum.

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

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