Supreme Court Sets Precedence in Determining Notional Income and Date of Birth in Accident Compensation Claims. Supreme Court revisits MACT award calculations, emphasizing proof of age, notional income standards, and fair compensation interest rates.


Summary of Judgement

 

  1. Case Background
    The appellants, the wife and sons of deceased Silak Ram, filed an appeal for compensation after a road accident in which Silak Ram succumbed to injuries (4 August 2015). The Motor Accident Claims Tribunal (MACT) awarded them compensation, later reduced by the High Court based on a different income estimate.

  2. Initial Award by MACT
    MACT awarded Rs.19,35,400 with 7.5% interest to the claimants. It used the deceased’s agricultural background and district wage rates to calculate notional income.

  3. High Court Re-evaluation and Reduction
    On appeal, the High Court reduced the compensation to Rs.9,22,336 by applying minimum state wage rates and altering the age multiplier based on the Aadhar Card. The High Court also reduced the interest rate from 7.5% to 6%.

  4. Appeal to the Supreme Court
    The claimants contested the High Court’s reduced amount, arguing for the original multiplier and challenging the notional income calculation and interest reduction.


Legal Issues and Ratio Decidendi

  1. Issue 1: Determining Age with Conflicting Documents
    The Supreme Court favored the School Leaving Certificate over the Aadhar Card for age determination, supported by Section 94 of the Juvenile Justice Act, 2015, recognizing school certificates as primary age evidence.

  2. Issue 2: Basis for Notional Income
    The Court held that district-specific wage rates (Rohtak’s Deputy Commissioner’s rates) were applicable rather than uniform state rates, given the deceased’s occupational specifics.

  3. Issue 3: Compensation and Interest
    The Supreme Court restored the 7.5% interest rate, raising it to 8% due to the compensatory nature of MACT claims, addressing both injury and death situations.


Acts and Sections Discussed

  • Sections 279/337, 304A of IPC: Pertains to offenses involving rash driving, causing hurt, and death due to negligence.
  • Section 94 of the Juvenile Justice (Care and Protection of Children) Act, 2015: Establishes school certificates as primary evidence in age determination cases.

Final Decision

The Supreme Court recalculated compensation based on a monthly income of Rs.9,000, an age multiplier of 14, and an 8% interest rate from the filing date. The final compensation totaled Rs.15,00,000, rounding up for just compensation.


Subjects:

Motor Accident Claims, Compensation, Determination of Age and Income, Judicial Precedence
Compensation Law, MACT, Motor Accident, Notional Income, Date of Birth Verification

The Judgement

Case Title: SAROJ & ORS. VERSUS  IFFCO-TOKIO GENERAL INSURANCE CO. & ORS.

Citation: 2024 LawText (SC) (10) 240

Case Number: CIVIL APPEAL NOS. OF 2024 (Arising out of SLP(C)Nos.23939-23940 of 2023)

Date of Decision: 2024-10-24