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Punjab and Haryana High Court Enhances Accident Compensation to ₹1.18 Crore, Recognises Homemaker’s Economic Value

Shivam Y.

Shilpa Jain (Since Deceased) through LRs & Ors. vs Inderjeet Jain & Ors. - Punjab and Haryana High Court enhances motor accident compensation to ₹1.18 crore, recognising homemaker’s income, pain, suffering and future medical costs.

Punjab and Haryana High Court Enhances Accident Compensation to ₹1.18 Crore, Recognises Homemaker’s Economic Value
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The Punjab and Haryana High Court has substantially enhanced compensation in a long-running motor accident case, raising the total amount payable to the family of a deceased homemaker from ₹58.22 lakh to ₹1.18 crore. The ruling came in an appeal filed by the legal heirs of Shilpa Jain, who remained in a vegetative state for over three years after a road accident before passing away.

Justice Sudeep­ti Sharma delivered the judgment on January 15, 2026, stressing that compensation under Section 166 of the Motor Vehicles Act must be “just, fair and realistic,” especially when the victim’s suffering is prolonged and severe .

Background of the Case

The case arose from a motor vehicle accident that occurred on October 8, 2014. Shilpa Jain sustained grievous injuries, including serious head trauma, and underwent prolonged treatment at multiple hospitals. Despite surgeries and intensive care, she never recovered and remained fully dependent on others until her death in November 2017.

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In 2016, the Motor Accident Claims Tribunal at Sirsa awarded her family ₹58.22 lakh with 9 percent annual interest. Dissatisfied, the claimants approached the High Court seeking enhancement, while the insurance company argued that the amount was already excessive, particularly under the head of future medical expenses.

Court’s Observations

The High Court confined itself to the question of compensation. It noted that the Tribunal had undervalued the contribution of the deceased by treating her income too conservatively.

The bench observed that the role of a homemaker goes far beyond unpaid domestic work.

“A housewife is not merely a skilled worker. Her contribution includes household management, childcare, emotional support, and care of the elderly, services which would otherwise require substantial expenditure,” the court said.

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Taking into account inflation and the year of the accident, the court reassessed Shilpa Jain’s notional monthly income at ₹15,000 and added 40 percent towards future prospects, following settled Supreme Court principles.

On pain and suffering, the court recorded that the victim lived for years in a complete vegetative state. Referring to recent Supreme Court rulings, Justice Sharma noted that such suffering cannot be measured mechanically.

“A healthy person reduced to total dependency suffers a profound loss of dignity and human experience,” the bench observed.

Key Findings on Compensation

The High Court also upheld the award of future medical expenses, rejecting the insurer’s argument that such amounts lapse after the victim’s death. It held that since the victim survived for a considerable period after the accident, these expenses formed part of her estate and were recoverable by her legal heirs.

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The court further allowed separate amounts for attendant charges, transportation, special diet, and loss of amenities, finding that the Tribunal had either ignored or inadequately assessed these heads.

Decision

Allowing the appeal, the High Court recalculated the compensation and fixed the total at ₹1,18,20,000. After deducting the amount already awarded by the Tribunal, the family became entitled to an enhanced sum of ₹59.98 lakh.

The court directed the insurance company to deposit the enhanced amount with 9 percent interest from the date of filing of the claim petition, within two months. The Tribunal was instructed to release the amount to the claimants in accordance with law.

Case Title: Shilpa Jain (Since Deceased) through LRs & Ors. vs Inderjeet Jain & Ors.

Case Number: FAO-4806-2017 (O&M)