Is the multiplier in a motor accident claim fixed by the age of the deceased or of the dependents?

Paragraph 13Further, it is argued on behalf of the Insurer that the multiplier applied in determining the compensation is erroneous. The compensation is awarded to the deceased's parents. Therefore, the multiplier ought to correspond to the age of the deceased's parents. The respondents argued that this argument is no longer res integra and that the binding precedents of this Court enable the Tribunal to consider the deceased's age when applying the multiplier. The MACT and the High Court rejected the Insurer’s argument, holding that the legal position has evolved and is now settled in favour of using the deceased’s age. The High Court relied on Sarla Verma v. Delhi Transport Corporation,[^1] which standardised the multiplier table, and subsequent Judgments began applying the deceased's age uniformly. Further, a Three-Judge Bench of this Court in Munna Lal Jain v. Vipin Kumar Sharma[^2] held that the multiplier should depend on the deceased’s age and not on the dependents’ ages. Further, the High Court, while relying on Sube Singh v. Shyam Singh,[^3] clarified that the issue “is no more res integra”. This Court, in Sube Singh (supra), affirmed the Munna Lal Jain (supra) ruling that the multiplier must depend on the age of the deceased bachelor, not the parents.

Paragraph 14To ensure consistent calculations across the country, this Court introduced a standardised multiplier matrix in Sarla Verma (supra). This matrix was validated by a Five-Judge Bench in Pranay Sethi.[^4] Addressing the specific legal question of which multiplier method would apply to the bachelors, a Three-Judge Bench of this Court in Munna Lal Jain (supra) held that the multiplier must be determined by the age of the deceased, not by the age of the dependents. This was later confirmed by a subsequent ruling of this Court in Sube Singh (supra), which held that this rule is no longer res integra. The deceased, Shushant Prabhakaran, was 33 years old at the time of the accident. According to the standardised matrix established in Sarla Verma (supra) and approved in Pranay Sethi (supra), the age bracket of 31 to 35 corresponds directly to a multiplier of 16. Therefore, the MACT and the High Court correctly applied a multiplier of 16 in determining the compensation.