Introduction:

In a landmark judgment, the Rajasthan High Court significantly enhanced the compensation awarded to the family of a deceased second-year MBBS student, Sunil Bishnoi, who tragically lost his life in a road accident. The Court criticised the Motor Accidents Claims Tribunal (MACT) for its unrealistic and hyper-technical approach in computing the deceased’s income based on the minimum wage of a skilled worker. Justice Arun Monga emphasized the necessity of a more compassionate and realistic assessment, recognizing the deceased’s academic achievements and future earning potential.

Arguments Presented:

Appellants’ Perspective:

The appellants, parents of the deceased, contended that the MACT erred by assessing their son’s income based solely on the minimum wage for a skilled worker, disregarding his status as a second-year MBBS student who had cleared the National Eligibility cum Entrance Test (NEET), one of India’s most challenging competitive exams. They argued that this approach failed to account for his promising future as a medical professional and sought a reassessment that reflected his true potential.

Respondents’ Perspective:

The insurance company, representing the respondents, argued that at the time of his death, the deceased was a student with no actual income and was financially dependent on his family. They maintained that the MACT’s reliance on the minimum wage standard was appropriate given the lack of concrete income evidence.

Court’s Observations and Judgment:

Justice Arun Monga, presiding over the case, found the MACT’s methodology to be overly rigid and disconnected from the realities of the deceased’s academic standing and future prospects. He noted that relying strictly on minimum wage standards for a student who had demonstrated exceptional academic merit devalued education and failed to provide restorative justice.

The Court referred to the Supreme Court’s decision in Bishnupriya Panda vs. Basanti Manjari Mohanty & Anr., where a fourth-year MBBS student’s notional income was assessed at ₹50,000 per month, with an additional 40% considered for prospects. Drawing from this precedent, Justice Monga assessed the deceased’s notional income at ₹70,000 per month, adding 40% for prospects, totalling ₹98,000 monthly. After deducting 50% for personal expenses, the dependency amount was calculated at ₹49,000 per month.

Applying the appropriate multiplier, the Court arrived at a total compensation of ₹1,05,84,000, a substantial increase from the ₹12,52,429 initially awarded by the MACT. This reassessment aimed to provide a more equitable compensation that acknowledged the deceased’s potential and the family’s loss.