Authority: Supreme Court of India, Civil Appellate Jurisdiction

Order Date: 1 July 2026

Case Overview

  • Civil Appeal No. ? of 2026 (SLP (C) No. 27220 of 2024) – Appellants Rashmirekha Tripathy & Anr. vs. Sriram General Insurance Co. Ltd. & Ors.
  • Accident on 29‑05‑2018; deceased Manoranjan Pandey (39) ran a construction business, claimed annual income Rs 15,00,000.
  • MACT awarded Rs 2,27,00,064 + 6% interest; High Court reduced to Rs 1,87,75,150 using average of two ITRs and multiplier 15.
  • SC appointed amicus counsel; held that for self‑employed the average of up to three prior‑year ITRs is appropriate, and fixed annual income at Rs 14,00,000.
  • Applying statutory multipliers and deductions, SC computed total compensation of Rs 1,97,81,505.
  • Civil Appeal No. ? of 2026 (SLP (C) No. 3088 of 2025) – Appellants Rajani & Ors. vs. Mukesh & Ors.
  • Accident on 08‑01‑2017; deceased Sushil (49), an insurance agent earning Rs 1,50,000 per month.
  • MACT awarded Rs 49,77,000 (monthly income Rs 40,000); High Court enhanced to Rs 76,09,500 (monthly income Rs 62,500).
  • SC observed High Court erred by averaging four ITRs; for a self‑employed professional, average of three prior ITRs is proper.
  • Using ITRs for AY 2015‑16, 2016‑17, 2017‑18, SC fixed annual income at Rs 6,87,802 and total compensation at Rs 87,09,282.
  • Civil Appeal No. ? of 2026 (SLP (C) No. 7735 of 2025) – Appellants Smt. Rekha & Ors. vs. Dinesh Porwal & Ors.
  • Accident on 15‑06‑2015; deceased Krishnavallabh (28), ran a wholesale grocery store, claimed annual income Rs 5,00,000.
  • MACT awarded Rs 15,36,560 (monthly income Rs 7,000); High Court enhanced to Rs 38,40,850 (monthly income Rs 16,750) using two pre‑death ITRs.
  • SC noted exclusion of two post‑death ITRs was improper; applied average of three prior ITRs (including one post‑death but justified) and set annual income at Rs 3,25,000.
  • Total compensation recomputed at Rs 60,79,550.

Guidelines Established by the Court

  • For salaried deceased, the immediately preceding year’s ITR suffices to determine annual income.
  • For self‑employed / business owners, the average of up to the last three years’ ITRs should be used, subject to consideration of business nature, growth pattern, and any anomalous income.
  • Multipliers and deductions follow established jurisprudence (e.g., multiplier 13‑16, 1/4 deduction, 10 % increase for certain heads).

Final Outcome

  • The Supreme Court allowed all three civil appeals, modified the compensation awards to Rs 1,97,81,505; Rs 87,09,282; and Rs 60,79,550 respectively.
  • Interest on the enhanced amounts as awarded by the respective MACTs shall continue to accrue.
  • The amounts are to be directly remitted into the claimants’ bank accounts within four weeks of the order, with account details to be furnished by counsel.
  • All pending applications, if any, are disposed of.

Topics: Motor Accident Compensation, Income Assessment Guidelines