New Delhi, Jun 23 The Supreme Court on Tuesday said the principle of awarding 'just compensation' under the Motor Vehicles Act was not one of exact mathematical equivalence, rather it was an attempt to provide a measure of solace to those who have suffered an irreparable loss.
A bench of justices Prashant Kumar Mishra and N V Anjaria refused to interfere with the compensation awarded to the parents of a 20-year-old man, who was pursuing Chartered Accountancy (Final) and died in a road accident in June 2013 in Delhi.
The bench observed that adjudication of compensation in the case cannot be viewed in sterile mathematical terms alone detached from human element underlying such claims.
It said the case before it concerns the loss of a young life with promising professional potential and the determination of compensation under the Act was ultimately guided by the principle of awarding 'just compensation'.
"This principle is not one of exact mathematical equivalence, rather it is an attempt by the law to provide a measure of solace, within human limitations, to those who have suffered an irreparable loss," the bench said.
The top court delivered its verdict on the appeals arising out of an August 2022 judgement of the Delhi High Court.
The high court had affirmed an order of the Motor Accident Claims Tribunal which had awarded a compensation of Rs 81.21 lakh to the victim's parents who had instituted a claim petition under the Motor Vehicles Act seeking compensation on account of the untimely death of their son.
Dealing with the issue of quantum of compensation, the top court noted the tribunal had proceeded to determine the monthly income of the deceased at Rs 55,500 by taking into account his educational progression, professional prospects and likely career advancement.
It said that while determining the monthly income, the tribunal had already departed from the actual stipend proved on record and proceeded to assess the income by taking into account his professional prospects and educational progression, his imminent entry into the profession of CA and the likely increase in earning capacity.
The bench said in this case, a young student had died on the threshold of a professional career.
"In the facts of the present case, we are of the considered view that reducing the compensation payable to the claimants at this stage on account of what is essentially a technical overlap in the methodology adopted by the tribunal would not advance the cause of substantive justice," the bench said.
It said the loss suffered by the parents of the deceased cannot be measured with arithmetical precision, and the compensation awarded, viewed holistically, cannot be said to transgress the bounds of 'just compensation' under the Act.
"The beneficial character of the legislation, the long passage of time since the accident, the concurrent assessment made by the tribunal and the high court, and the impossibility of placing a precise monetary value upon the loss of a young life, together persuade us not to disturb the compensation awarded towards loss of dependency," it said.
The bench also noted that compensation cannot be founded on assumptions of assured professional success or on salary benchmarks of unrelated successful professionals.
"The life of a young individual and the loss suffered by his family cannot be measured in precise monetary terms, and the determination of 'just compensation' under the MV Act does not admit of mathematical exactitude," it said.
"In the facts of the present case, the claimants, being the parents of the deceased unmarried son, are entitled to compensation under the head of 'filial consortium'," it said.
The bench directed that in addition to the compensation already awarded, the claimants would be entitled to Rs 40,000 each towards filial consortium.
It said the total compensation payable to the claimants would stand enhanced from Rs 81,21,900 to Rs 82,01,900 along with interest in terms of the award of the tribunal.
