Courts Must Rise Above Rigid Arithmetical Calculations: Rajasthan High Court Enhances Motor Accident Compensation To Over Rs 1 Crore For Medical Student’s Death

The appeal before the High Court was filed by a grieving couple, whose 20-year-old son, who was a promising medical student, died in a motor accident. The parents sought enhancement of compensation by modification of the impugned judgment passed in a Claim Case by the Motor Accident Claims Tribunal, Bikaner.

The Single Bench of Justice Arun Monga asserted, “I am of the considered opinion that in cases of the nature, as the one in hand, when dealing with young professionals-in-training, courts must rise above the rigid arithmetical calculations and insistence of income proof. A purely mathematical or minimum-wage-based approach risks devaluing education, aspiration, and merit — which are highly valued and zealously protected by the law. Apart therefrom, realistic compensation not only ensures restorative justice for the bereaved family but also serves as a deterrent to negligent driving, reinforcing accountability in road safety.”

Advocate Aman Bishnoi represented the Appellant while Advocate TRS Sodha represented the Respondents.

Factual Background

The incident dates back to the year 2019 when the student Sunil Bishnoi was travelling in a Car from Jodhpur to Udaipur, along with his friends. When the vehicle reached near Bhairunath Dhaba, its driver (son of the first respondent), due to rash and negligent driving, hit a motorcycle. As a result, the car driver lost its control and collided with a road divider, leading to injuries from iron angles installed along the divider.

Sunil Bishnoi sustained grievous injuries in the accident and, despite medical efforts, succumbed to his injuries. All parties to the claim petition actively participated in the proceedings. The Tribunal awarded total compensation of Rs 12,52,429 to the appellants. Finding the compensation amount awarded inadequate, the appellants filed the present appeal.

Reasoning

On a perusal of the impugned award, the Bench found that the Tribunal's approach was wholly unrealistic, unduly pedantic, hyper-technical and very narrow, leading to too low an assessment of the income potential of the deceased. “The MACT awarded ₹12,52,429 based on the minimum wage for a skilled worker (₹7,774/- per month), even though the deceased, Sunil Bishnoi, was a second-year MBBS student, having cleared NEET — one of India’s toughest competitive exams”, it said.

The Bench further highlighted the fact that on completion of professional courses like MBBS or engineering, such students have the potential to earn far above and multiple times the minimum wage of a skilled worker. The Tribunal rejected the claim of income of ₹25,000 per month in tuition earnings due to a lack of documentary proof.

“However, it failed to make a realistic assessment and apply judicial mind to the deceased’s academic trajectory while assessing his potential future earnings. Thus, the learned Tribunal committed a manifest error in law by applying a rigid and overly conservative formula for assessment of notional income to a case where the deceased’s future earnings and familial contribution were clearly poised for excellence. A corrective and compassionate course is warranted in the case in hand”, the Bench stated.

It was further held that the award needed to be modified for upward reassessment of his notional income. Assessing the income potential of the deceased at the time of his death in 2019 as Rs. 70,000 per month, the Bench awarded an enhanced compensation of Rs. 1,07,21,500.

Cause Title: Indra W/o Rajaram & Anr. v. Jagdish Chandra (Neutral Citation: 2025:RJ-JD:20488)

Appearance

Appellants: Advocate Aman Bishnoi

Respondents: Advocate TRS Sodha

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