Future prospects and revised conventional heads raised motor accident compensation in a fatal claim.

Compensation in a fatal motor accident claim under Section 166 of the Motor Vehicles Act, 1988 was enhanced because just, fair and reasonable compensation required addition of future prospects even where income was not fully proved. The Court applied a 30% increase for future prospects, retained the one-third deduction for personal expenses, and upheld the multiplier of 17. It also revised the conventional heads, bringing the amounts for loss of consortium and funeral expenses into line with recent judicial principles. The award was therefore modified in favour of the appellant.

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Issues: Whether the compensation awarded for a fatal motor accident claim required enhancement by adding future prospects and by revising the amounts under the conventional heads.

Analysis: The claim arose under Section 166 of the Motor Vehicles Act, 1988. The Court held that compensation in motor accident cases must be just, fair and reasonable, and that the assessment cannot remain confined to technical or outdated conventional figures. It accepted the need to add future prospects to the notional income even where the income was not fully proved, applied a 30% increase for future prospects, retained the one-third deduction towards personal expenses, and upheld the multiplier of 17. It also revised the conventional heads, holding that the amounts for loss of consortium and funeral expenses had to be brought in line with the principles recognised in recent decisions.

Conclusion: The compensation was enhanced to include future prospects and revised conventional heads, and the award was modified in favour of the appellant.

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