Summary
The Supreme Court held that the motor-accident multiplier depended on the deceased’s age, not his parents’ ages. For the unmarried deceased aged twenty-three, multiplier eighteen replaced the High Court’s fourteen. On the annual family contribution already determined, loss-of-dependency compensation became Rs.6,80,400. Other compensation heads remained undisturbed and interest was increased to 9% per annum.
Issues
- Whether the age of the deceased or dependent parents governed the multiplier for loss of dependency.
Held
- Following the three-Judge decision in Munna Lal Jain and the Sarla Verma approach affirmed in Pranay Sethi, the multiplier must be selected by the deceased’s age. The parents’ ages of forty to forty-five did not justify multiplier fourteen for their twenty-three-year-old son. (¶¶ 1, 2, 3, 4)
- Multiplier eighteen applied to the already determined annual contribution of Rs.37,800 yielded Rs.6,80,400 instead of Rs.5,29,200. Other heads awarded by the High Court were preserved and the interest rate was increased from 6% to 9% per annum. (¶¶ 5, 6)
Result
Appeal allowed without costs; multiplier increased to eighteen, resulting in Rs.6,80,400 for the stated dependency calculation; other heads preserved and interest modified to 9% per annum.