Homemaker’s Work Not Equal To Unskilled Labour: Madhya Pradesh High Court Enhances Compensation

The Madhya Pradesh High Court has reaffirmed the economic value of a homemaker’s contribution while enhancing compensation in a motor accident claim, holding that domestic work cannot be undervalued or equated with unskilled labour.

Deciding a miscellaneous appeal, Justice Hirdesh sitting at the Gwalior Bench modified an award passed by the Motor Accident Claims Tribunal and nearly doubled the compensation payable to the claimants, underscoring the need for a realistic assessment of a deceased woman’s role within the household.

The appeal, filed by Manoj and others under Section 173(1) of the Motor Vehicles Act, challenged the Tribunal’s award dated February 28, 2019, which had granted compensation of Rs. 6,97,200 along with interest for the death of Mamta in a motor accident. Notably, the findings on negligence and liability were not in dispute before the High Court, allowing the Bench to focus solely on whether the compensation awarded was just and reasonable.

Appearing for the appellants, Advocate Ashok Kumar Yadav argued that the Tribunal had erred in assessing the income of the deceased at an unrealistically low figure. It was submitted that Mamta was engaged in beautician work and that her income had not been properly appreciated. The counsel further contended that the Tribunal failed to award adequate amounts under conventional heads such as loss of estate and funeral expenses, thereby warranting enhancement. On the other hand, Deputy Solicitor General Praveen Kumar Newaskar, representing the respondents, supported the Tribunal’s findings and sought dismissal of the appeal.

After hearing both sides and examining the record, the Court found merit in the appellants’ grievance. It noted that the Tribunal had assessed the deceased’s monthly income at Rs. 3,500 in the absence of documentary proof, but such an approach failed to capture the true value of her contribution. The Court observed that “a homemaker renders multifarious services to the family, manages the entire household without fixed working hours and without any leave,” and therefore her work cannot be treated at par with that of an unskilled labourer.

Taking a more pragmatic view, the Bench held that even in the absence of strict proof of income from beautician work, the deceased’s earnings ought to have been assessed at least at the level of a semi-skilled worker under the Minimum Wages Act. At the relevant time, this was pegged at Rs. 5,975 per month. The Court concluded that the Tribunal had committed an error in undervaluing the income and corrected the same accordingly.

The Court further applied established principles laid down by the Supreme Court in cases such as National Insurance Company Ltd. v. Pranay Sethi and Sarla Verma & Ors. v. Delhi Transport Corporation & Anr., affirming the addition of 40 percent towards future prospects and the use of multiplier 16 based on the age of the deceased. It also granted compensation under conventional heads, including loss of consortium, loss of estate, and funeral expenses, in line with prevailing jurisprudence.

Recalculating the compensation, the Court arrived at a total figure of Rs. 12,20,720. This represented a substantial increase from the Tribunal’s award, entitling the claimants to an additional sum of Rs. 5,23,520. The Bench held that this amount constituted “just and proper compensation” in the facts of the case.

Accordingly, the appeal was partly allowed, and the impugned award was modified. The Court directed that the enhanced compensation would carry interest at the same rate as previously awarded and must be paid within three months from receipt of the certified copy of the order. It also directed the appellants to deposit any differential court fee, if required, within one month.

Case Title: Manoj and Others v. Arvind Kumar Jha and Others

Date of Order: March 26, 2026

Bench: Justice Hirdesh