No Bar On Awarding Higher Compensation Than Claimed In Motor Accident Claims: Andhra Pradesh HC

Courts are duty-bound to award just compensation under motor accident claim proceedings and are not restricted by the specific amount claimed by the victims or their dependents. Dismantling procedural technicalities, the High Court held that beneficial welfare legislation must prioritize equitable relief over rigid claim limits.

A single-judge bench comprising Justice A. Hari Haranadha Sarma heard the motor accident civil miscellaneous appeal challenging the adequacy of the compensation awarded by the Motor Accident Claims Tribunal (MACT). The appeal was preferred by the parents of a 24-year-old deceased victim, seeking an enhancement of the Rs. 2,13,500/- awarded against their original claim of Rs. 5,00,000/-.

Tribunal's Assessment Overhauled

The High Court held that the tribunal erred in calculating the compensation based on the age of the dependents rather than the age of the deceased, directly violating established precedents. Re-assessing the multiplicand and multiplier according to settled law, the Court applied a multiplier of 18 corresponding to the deceased's age of 24 years, added 30% for future prospects, and deducted 50% towards personal expenses since the deceased was unmarried.

The Court has following directions:

"(i) Compensation awarded by the learned MACT in M.O.P.No.442 of 2010 at Rs.2,13,500/- with interest at the rate of 7.5% per annum is modified and enhanced to Rs.10,02,400/- with interest at the rate of 6% per annum from the date of petition till the date of realization.
(ii) Claimants are liable to pay the Court fee for the enhanced part of the compensation, before the learned MACT.
(iii) Apportionment:
(a) Claimant No.1 / mother of the deceased is entitled to Rs.6,02,400/- with proportionate interest and costs.
(b) Claimant No.2 / father of the deceased is entitled to Rs.4,00,000/- with proportionate interest.
(iv) Respondent Nos.1 and 2 before the learned MACT are jointly and severally liable to pay the compensation. However, respondent No.2 / Insurance Company is liable in view of the insurance policy.
(v) Time for payment /deposit of balance amount is two months.
(a) If the claimants furnish the bank account number within 15 days from today, the respondents shall deposit the amount directly into the bank account of the claimants and file the necessary proof before the learned MACT.
(b) If the claimants fail to comply v(a) above, the respondent No.2 / Insurance Company shall deposit the amount before the learned MACT and the claimants are entitled to withdraw the amount at once on deposit.
(vi) There shall be no order as to costs, in the appeal."

In evaluating the legal principles governing full and fair recovery under welfare enactments, the Court, in its reasoning, observed: "The legal position with regard to awarding more compensation than what claimed has been considered and settled by the Hon'ble Supreme Court holding that there is no bar for awarding more compensation than what is claimed... The function of the Tribunal or Court under Section 168 of the Motor Vehicles Act, 1988 is to award 'just compensation'. The Motor Vehicles Act is a beneficial and welfare legislation. A 'just compensation' is one which is reasonable on the basis of evidence produced on record."

Background:

The dispute arose from a fatal road traffic accident on February 10, 2009, involving a motorcycle on which the deceased was traveling as a pillion rider. Due to rash and negligent driving by the vehicle owner, the deceased sustained critical head injuries and later succumbed to them. The claimants filed a petition under Section 166 of the Motor Vehicles Act, 1988 before the tribunal claiming Rs. 5,00,000/-, but were awarded Rs. 2,13,500/-.

While computing the award, the MACT erroneously applied a multiplier of 9 based on the average age of the parents and reduced the victim's proven monthly income of Rs. 6,000/- to Rs. 3,000/- without incorporating future prospects. Aggrieved by the inadequate quantum, the claimants preferred an appeal under Order 41 of the Code of Civil Procedure, 1908 before the High Court.

In its determination, the High Court relied on Sarla Verma (Smt.) and Ors. Vs. Delhi Transport Corporation and Anr. and National Insurance Company Ltd. v. Pranay Sethi and Others ( "2017(16) SCC 680": 2017 CaseBase(SC) 551) to calculate the multiplicand and add future prospects. For conventional heads and parental consortium, the Court applied Magma General Insurance Company Ltd. v. Nanu Ram and Others ( "(2018) 18 SCC 130": 2018 CaseBase(SC) 597). Adopting the overriding duty to award just compensation established in Rajesh and others vs. Rajbir Singh and others, Nagappa Vs. Gurudayal Singh and Others ( "(2003) 2 SCC 274": 2002 CaseBase(SC) 1060), Kajal Vs. Jagadish Chand and Ors. ( "2020 (04) SCC 413": 2020 CaseBase(SC) 1600), and Ramla and Others Vs. National Insurance Company Limited and Others ( "(2019) 2 SCC 192": 2018 CaseBase(SC) 651), the High Court enhanced the total compensation to Rs. 10,02,400/-.

Case Details:
Case No.: M.A.C.M.A. No. 912 of 2014
NeutralCitation: 2026:APHC:29738
Case Title: Smt. Chiriki Demudamma & Another v. Mr. Rongali Demudu Naidu & Another
Appearances:
For the Petitioner(s): Jayanti S C Sekhar
For the Respondent(s): Gudi Srinivasu

Source: 2026 CaseBase(AP) 3755