The Rajasthan High Court underscored that contribution of a Homemaker is significant and invaluable and observed that the services of homemakers must be given pecuniary value while awarding compensation in motor accident and similar claims.

The Tribunal awarded compensation of Rs.4,33,000/-, which was enhanced by the High Court to Rs. 7,48,720/-.

The Bench of Justice Nupur Bhati observed, “The Hon’ble Apex Court in the catena of judgments has consistently recognized the significant and invaluable contribution of homemakers and has time and again, held that services of homemakers must be given pecuniary value while awarding compensation in motor accident and similar claims.”

Advocate Praveen Choudhary represented the Petitioner, while Advocate Vishal Singhal represented the Respondent.

Case Brief

An Appeal was filed by the claimant under Section 173 of the Motor Vehicles Act, 1988, challenging the validity of award dated passed by the Motor Accidents Claim Tribunal, whereby the Tribunal has partly allowed the claim petition of the claimant and awarded an amount of compensation to the tune of Rs.4,33,000/- in total with the interest @ 9% p.a.

The deceased woman was hit by a Bolero Jeep driven rashly and negligently and a claim petition was initiated by the husband of the deceased woman. Being aggrieved by the meagre amount of compensation awarded by the Tribunal, the husband filed the appeal.

It was submitted that the notional income of a homemaker cannot be undervalued. While the insurance company submitted that a homemaker’s contribution is not to be equated with actual employment income.

Court’s Observation

At the outset, the High Court said that the Tribunal has not awarded compensation under the non-pecuniary heads viz. Consortium and Loss of Estate. “ It is worthwhile to mention here that the learned Tribunal has assessed the income of the deceased as Rs.3,000/-, whereas, looking to the peculiar facts and circumstances of the case, this Court deems it appropriate to assess the income of the deceased as per the minimum wages of the skilled labour prevalent at the time of the untoward incident i.e. in the year 2011, which will be Rs.4,650/-”, the Court added.

Further, the High Court underscored that the Supreme Court has consistently recognized the significant and invaluable contribution of homemakers and has time and again held that services of homemakers must be given pecuniary value while awarding compensation in motor accident and similar claims.

Crucially, the High Court enhanced the amount of compensation awarded by Rs. 3,15,720/- and the Appeal was partially allowed.

Cause Title: Lrs Of Purakh Singh V. Narendra Singh (Neutral Citation: 2025:RJ-JD:43222)

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