Court’s Decision:
The Supreme Court restored the compensation amount to Rs. 15,00,000 with 8% interest in a motor accident case. The Court upheld the Motor Accident Claims Tribunal’s (MACT) decision regarding the notional income and age of the deceased, reversing the High Court’s reduction of the compensation. The Court also emphasized that compensation should be just and reasonable, enhancing the interest rate to 8%.
Facts:
The case arose from a motor accident on August 4, 2015, in which the deceased, Silak Ram, was traveling on a motorcycle. Both the deceased and another person, Rohit, were found injured on the roadside. Silak Ram succumbed to his injuries, and Rohit was taken to the hospital for treatment. An FIR was registered, and a claim petition was filed by the family of the deceased before the MACT, Rohtak, which awarded Rs. 19,35,400 as compensation. However, the High Court reduced this amount to Rs. 9,22,336 based on a different calculation of the notional income and age of the deceased.
Issues:
- Which document should be considered authoritative for determining the age of the deceased: the Aadhar Card or the School Leaving Certificate?
- Was the High Court’s reduction of the compensation awarded by the MACT justified?
Petitioner’s Arguments:
The petitioners contended that the multiplier applicable should be 14, as the School Leaving Certificate recorded the deceased’s date of birth as October 7, 1970, making him 45 years old at the time of the accident. They also argued that the High Court incorrectly calculated the deceased’s monthly income as Rs. 5,886, which led to a reduced compensation amount.
Respondent’s Arguments:
The respondents supported the High Court’s decision, which relied on the deceased’s Aadhar Card that listed his date of birth as January 1, 1969, making him 47 years old at the time of the accident. The High Court used a multiplier of 13 and based its calculation on minimum wage rates applicable throughout the state.
Analysis of the Law:
The Court examined the admissibility of documents for age determination under Section 94 of the Juvenile Justice Act, 2015, which gives precedence to the School Leaving Certificate over other documents like the Aadhar Card when determining a person’s age. The Court also discussed the principles of appellate review, emphasizing that an appellate court should not substitute its view for that of the lower court unless there is perversity or illegality in the decision.
Precedent Analysis:
The Court referred to National Insurance Co. Ltd. v. Pranay Sethi and other cases related to the determination of compensation in motor accident claims. These precedents establish guidelines for calculating notional income, multipliers, and future prospects.
Court’s Reasoning:
The Supreme Court held that the High Court erred by disregarding the School Leaving Certificate, which should have been used to determine the deceased’s age, and by reducing the compensation without sufficient grounds. The Court noted that the School Leaving Certificate was a more reliable document for determining the deceased’s age than the Aadhar Card. The Court also found no reason to interfere with the MACT’s calculation of the deceased’s notional income and its use of a multiplier of 14.
Conclusion:
The Supreme Court allowed the appeal and restored the compensation to Rs. 15,00,000, including 8% interest from the date of filing of the claim petition.
Implications:
The judgment reiterates the importance of just compensation in motor accident cases, reinforcing the precedence of statutory documents like the School Leaving Certificate over other identification documents for age determination. It also clarifies the role of appellate courts in reviewing compensation awards, ensuring that victims’ families receive fair compensation.