The Supreme Court of India has enhanced the compensation for the family of Rajinder Singh Mihnas, a 31-year-old US-based driver and transport company owner who died in a road accident in Karnal in 2007. The Court awarded an additional ₹42,95,080 along with 6% interest, recognizing the benefit of ‘future prospects’ as per the landmark Pranay Sethi judgment.
Case Background
On 31 August 2007, at around 3:00 a.m., Rajinder Singh was travelling from Delhi to Hoshiarpur in a car driven by Devender Singh when a Swaraj Mazda truck, driven rashly, collided with the vehicle at Nirmal Kutia Chowk, Karnal. Singh, a US national, died in the accident.
At the time of his death, Singh ran West End Express Inc. in the United States, reportedly earning $9,600 (₹4.25 lakh) per month. His wife, daughter, and parents filed a claim under Section 166 of the Motor Vehicles Act.
- Motor Accident Claims Tribunal (MACT):
Considered Singh’s income at only ₹5,000 per month, citing lack of verified US wage details. It awarded ₹7,80,000 with 6% interest. - Punjab & Haryana High Court:
Relied on US minimum wage data and Singh’s verified employment documents, fixing his monthly income at ₹78,300 and enhancing the compensation to ₹1,17,20,200. However, it did not add future prospects.
The appellants argued that the High Court erred in not including future prospects. Referring to National Insurance Co. Ltd. v. Pranay Sethi, the Court held that:
“A self-employed person is also entitled to an increase in income over time… Addition of 40% of the established income where the deceased was below 40 years is reasonable.”
The Court accepted the High Court’s income assessment but added 40% future prospects. It also adjusted amounts under loss of estate, loss of consortium, and funeral expenses as per Pranay Sethi.
| Head | Revised Amount (₹) |
|---|---|
| Loss of Dependency | 1,57,85,280 |
| Loss of Consortium | 1,60,000 |
| Loss of Estate | 15,000 |
| Funeral Expenses | 15,000 |
| Total | 1,60,15,280 |
This means the family will now receive an additional ₹42,95,080 over the earlier award, with 6% interest to be paid within four weeks.
The insurance company must deposit the additional amount with interest before the Tribunal. The claimants can withdraw the amount after verification.
Case Details: Kulwinder Kaur & Ors. vs. Parshant Sharma & Anr.
Case Type: Civil Appeal No. 820/2019
Date of Judgment: 8 August 2025
Appellants: Kulwinder Kaur (wife of deceased) & Others (daughter, parents)
Respondents: Parshant Sharma & Another (including Insurance Company)