Bhagya Vs the Managing Director — Motor Accident Claims | Karnataka HC (2026)

Bhagya Vs the Managing Director — Motor Accident Claims | Karnataka HC (2026)

What the court decided

AI extract

Outcome

MFA No.1991/2024 (claimants' enhancement appeal) dismissed; MFA No.7227/2023 (KSRTC's appeal) allowed; judgment and award dated 13.03.2023 in MVC No.1194/2021 modified reducing compensation to Rs.20,24,000/- with interest at 6% per annum; KSRTC directed to deposit the balance compensation with interest within one month from the date of the order; on deposit, appellants permitted to withdraw the amounts equally; the amount in deposit to be transmitted to the Tribunal.

Issue for consideration

Whether the compensation of Rs.21,81,000/- awarded by the Tribunal warranted enhancement, having regard to the income of the deceased, the applicable multiplier and additions/deductions. +2 more

Court's answer

The claimants filed no document to prove the deceased's income; the notional monthly income of Rs.15,000/- was confirmed as per the chart prepared by the Karnataka Legal Services Authority and the Court found no reason to interfere with it.

Ratio / Principle

Since the deceased Suresh was aged 32 years, the appropriate multiplier adopted is '16'.

Key takeaways

'Loss of dependency' computed at Rs.20,16,000/- [(Rs.15,000/- + 40% - 50%) x 12 x 16], adding 40% towards future prospects per Pranay Sethi and deducting 50% towards personal expenses as the deceased was a bachelor per Sarla Verma; additionally Rs.33,000/- awarded towards 'conventional heads' per Pranay Sethi.ratio¶96
The interim compensation of Rs.25,000/- granted by the corporation on humanitarian ground had to be deducted from the total compensation of Rs.20,49,000/- (printed as 'Rs.2049,000/-'), taking it to Rs.20,24,000/-.ratio¶101

Detailed headnote1 paragraphs

HIGH COURT OF KARNATAKA AT BENGALURU (P Sree Sudha, J.) — Connected Miscellaneous First Appeals under S.173(1) MV Act against the award dated 13.03.2023 in MVC No.1194/2021 (III Addl. District & Sessions Judge, AMACT, Tumakuru), arising from the death of Suresh K (aged 32, bachelor) in an accident on 21.09.2021. The Tribunal had partly allowed the claim of the deceased's sisters and brother (Class-II legal heirs) awarding Rs.21,81,000/- with 6% interest. The claimants sought enhancement contending income of Rs.20,000/- p.m.; KSRTC appealed contending the claimants, being married sisters and an employed brother not dependent on the deceased, were entitled only under 'loss of estate' and that the interim compensation of Rs.25,000/- paid by it was not deducted. HELD: (i) with no document proving income, the notional income of Rs.15,000/- p.m. per the Karnataka Legal Services Authority chart stands confirmed and was not disturbed; (ii) for age 32, multiplier '16' applies; adding 40% towards future prospects (per Pranay Sethi) and deducting 50% towards personal expenses as the deceased was a bachelor (per Sarla Verma), loss of dependency works out to Rs.20,16,000/-; (iii) Rs.33,000/- added towards conventional heads per Pranay Sethi, totalling Rs.20,49,000/-; (iv) the interim compensation of Rs.25,000/- is deducted, fixing compensation at Rs.20,24,000/- with 6% interest. RESULT: Claimants' MFA No.1991/2024 dismissed; KSRTC's MFA No.7227/2023 allowed; Tribunal award modified to Rs.20,24,000/-; KSRTC to deposit the balance with interest within one month, equal withdrawal permitted and the deposit transmitted to the Tribunal. Precedents applied: Pranay Sethi; Sarla Verma. Referred to (on counsel's arguments): Gujarat State RTC v. Ramanbhai Prabhatbhai; NIC v. Birender; MD KSRTC v. Venkataramanappa; A. Manavalagan; NIC v. George Menezes (Kar HC, 17.10.2025).