Dismissed¶¶24

Ram Pal v. Baljit Singh and Others

Punjab & Haryana HC21 Jan 2026FAO/2352/2022

Case brief

AI extract

What is this about?

Punjab and Haryana High Court, FAO-2352-2022, Ram Pal v. Baljit Singh and Others (Archana Puri, J., decided 21.01.2026): enhancement of MACT compensation in a death case refused. Income of deceased taken at Rs.15,000/- per month held appropriate despite claimed earnings of Rs.30,000/-; no future prospects addition, personal expenses deduction and multiplier of 7 upheld for a 62-year-old deceased; loss of consortium not separately awarded as Rs.1,00,000/- for loss of love and affection covers it; appeal dismissed.

What did the court decide?

The income of the deceased taken by the Tribunal at Rs.15,000/- per month, which was above that of a highly skilled worker, is appropriate given the paucity of evidence regarding his earnings. ¶¶20

Ram Pal Vs Baljit Singh and Others — Punjab & Haryana HC (2026) — LawSathi Research

What the court decided

AI extract

Outcome

Dismissed

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Issue for consideration

Whether the compensation awarded by the Motor Accident Claims Tribunal on account of the death of Prem Nath in the motor vehicular accident required enhancement (including assessment of income, future prospects, deduction for personal expenses and multiplier). +1 more

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Court's answer

The income of the deceased taken by the Tribunal at Rs.15,000/- per month, which was above that of a highly skilled worker, is appropriate given the paucity of evidence regarding his earnings.

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Ratio / Principle

Keeping in view the age of the deceased, no further addition on the count of future prospects is to be made.

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Key takeaways

The deduction made on the count of personal expenses is appropriate.ratio¶¶21
Considering the age of the deceased, the application of the multiplier of 7 is appropriate.ratio¶¶21
No separate amount is required on the count of loss of consortium, as the Rs.1,00,000/- awarded by the Tribunal for loss of love and affection is comprehended in loss of consortium; adjusting that amount towards consortium for both appellants results in practically no change, calling only for nominal deduction.ratio

Detailed headnote1 paragraphs

Motor Accident Claims Tribunal award in a fatal motor vehicular accident case upheld; appeal for enhancement dismissed. The deceased (62 years) was alleged to be a skilled driver earning Rs.30,000/- per month, but with only the driving licence and passport on record, the Tribunal's assessment of income at Rs.15,000/- per month was held appropriate. Considering the deceased's age, no addition for future prospects, the deduction for personal expenses, and the multiplier of 7 were each held appropriate. On conventional heads, no separate amount for loss of consortium was found necessary, as the Rs.1,00,000/- already awarded for loss of love and affection comprehends loss of consortium, and adjusting it towards consortium for both appellants would result in practically no change. The Court declined to disturb the compensation earlier granted and dismissed the appeal.

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FAO-2352-2022

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IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH

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Sr. No.155-1

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FAO-2352-2022 Date of Decision: 21.01.2026

RAM PAL

....Appellant

Versus

BALJIT SINGH AND OTHERS

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.....Respondents

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CORAM: HON'BLE MRS. JUSTICE ARCHANA PURI

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Present:Mr. Parminder Singh, Advocate for the appellant.

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ARCHANA PURI, J. (Oral)

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The present appeal has been filed by the appellant-claimant, for seeking enhancement of compensation awarded by learned Motor Accident Claims Tribunal, on account of death of Prem Nath, in a motor vehicular accident.

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From the impugned award, it is evident that the deceased was 62 years old and was allegedly working as a skilled driver and his earnings were stated to be Rs.30,000/- per month. Admittedly, it is submitted by the counsel that apart from the driving licence and passport, there is no other material coming on record, with regard to Prem Nath-deceased, working as skilled worker. Even if, it is taken that he was working as driver, then also, in view of paucity of evidence, with regard to extent of earnings, learned Tribunal had considered the income of deceased as Rs.15,000/- per month,

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PREETI 2026.01.27 14:56 I attest to the accuracy and integrity of this document

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FAO-2352-2022

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which was above, than that of a highly skilled worker and as such, the extent of income, so taken, is appropriate.

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Keeping in view the age of the deceased, no further addition on the count of future prospects is to be made. The deduction made on the count of ‘personal expenses’ is also appropriate. Considering the age of the deceased, the application of multiplier of ‘7’ is also appropriate.

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However, counsel for the appellant-claimant, now submits that there is scope for enhancement under the conventional heads, as no amount, on the count of ‘loss of consortium’ has been awarded.

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Though, under the count of loss of consortium, the amount prevalent at present is Rs.48,400/-, but however, it ought to be taken into consideration that learned Tribunal had awarded the amount of Rs.1,00,000/-, on the count of loss of love and affection, which is comprehended in the loss of consortium and no separate amount is required to be given, on the count of ‘loss of love and affection’. Considering the same, and adjusting this amount towards loss of consortium, to both the appellants, there is practically not much change. Rather it calls for some deduction, which is also very nominal.

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In the given circumstances, this Court deems it appropriate not to further disturb the compensation earlier granted. Hence, there is no scope for further enhancement and as such, the appeal is hereby dismissed.

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(ARCHANA PURI) 21.01.2026 JUDGE Preeti S.

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Whether speaking/reasoned : Yes Whether reportable : Yes/No

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PREETI 2026.01.27 14:56 I attest to the accuracy and integrity of this document

Ram Pal v. Baljit Singh and Others

Case brief

What is this about?

What did the court decide?

Ram Pal v. Baljit Singh and Others

Case brief

What is this about?

What did the court decide?

What the court decided

Issues for consideration

Procedural history

Parties & counsel

Coram

Case details

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