Constitution of India (COI) – Motor Vehicles Act, 1988 (MVA) – Civil Procedure Code, 1908 (CPC)

National Insurance Co. Ltd. v. Pranay Sethi (2017) 16 SCC 680 – Malarvizhi & Ors. v. United India Insurance Co. Ltd. (2020) 4 SCC 228 – New India Assurance Co. Ltd. v. Sonigra Juhi Uttamchand 2025 SCC OnLine SC 9 – Appeal allowed; compensation enhanced to Rs.24,53,280/- with interest as awarded by the Tribunal.

Held: Income Tax Returns are statutory documents and must be considered for determining income (Para 7).  Enhanced compensation to Rs.24,53,280/- using multiplier method, considering future prospects (Para 9).

Subjects: Motor Vehicle Accident – Compensation – Income Tax Returns – Future Prospects – Multiplier – Loss of Consortium – Rash and Negligent Driving – Mechanical Engineer – National Insurance Co. Ltd. v. Pranay Sethi – Malarvizhi v. United India Insurance – New India Assurance v. Sonigra Juhi Uttamchand – MACT – Karnataka High Court

Facts: a. Nature of the litigation – Appeal for enhancement of compensation in motor accident claim. b. Appellant (wife of deceased) sought compensation of Rs.1,00,00,000/- due to death of her husband in a motor accident on 30th September, 2012. c. Reason – Tribunal awarded Rs.13,91,300/-, which appellant contended was inadequate. d. Previous decisions – Tribunal awarded Rs.13,91,300/-; High Court dismissed appeal for enhancement.

Issues: i. Whether Income Tax Returns can be relied upon for determining the income of the deceased? ii. Whether the compensation awarded by the Tribunal and High Court was just and proper?

Submissions/Arguments: a. Appellant – Income Tax Returns prove income; Tribunal and High Court erred in assessing income. b. Respondent – Tribunal's computation was correct; no scope for enhancement.

Ratio Decidendi:

• Income Tax Returns are admissible evidence for income calculation in motor accident claims.

• Compensation must include future prospects and apply correct multiplier.