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Chhattisgarh High Court Enhances Accident By 37 Lakhs Citing Income Tax Return Records
In a significant ruling for , the has emphasized the evidentiary weight of Income Tax Returns (ITR) when calculating for a . Justice Sanjay K. Agrawal, presiding over the matter, overturned a lower tribunal's decision that had dismissed the deceased's filed income tax records, ultimately increasing the awarded by over ₹37 lakh.
The Dispute and Initial Award
The litigation stemmed from a motor accident involving the death of Gajadhar Verma. His surviving family members— Smt. Gulab Verma, her children, and her mother-in-law—approached the High Court seeking an enhancement of the originally awarded by the . While the tribunal had approved a payout of ₹14,08,000, it had largely ignored the ITRs submitted by the family, which indicated a significantly higher income than the ₹7,000 per month attributed to the deceased by the tribunal. Simultaneously, had challenged the imposed upon it.
Legal Arguments and Judicial Scrutiny
The argued that the deceased, who worked in construction, was a regular tax-filer and that the tribunal’s decision to disregard the official income documentation was legally flawed. The Insurance Company countered this, asserting that the tribunal's initial assessment was accurate and that the ITRs should not form the basis for calculation due to their estimative nature.
The High Court rejected the tribunal's approach, noting that failing to consider verified tax documents without evidence of fraud or manipulation is unsustainable.
"The Income Tax Returns, having been duly produced and exhibited, constitute
for determining the income of the deceased,"
the Court observed, reinforcing that such documents should be treated as mandatory for determining
.
Key Observations from the Court
The judgment highlights a shift toward prioritizing documented income over subjective estimation in accident claims:
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"The Income Tax Returns, having been duly produced and exhibited, constitute for determining the income of the deceased."
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"In the absence of any material to establish that the returns were fabricated, manipulated or otherwise unreliable, there was no justification for ignoring the income disclosed therein."
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"In case of , ITR will be considered as a mandatory document and as a result of which, the income of the deceased deserves to be assessed on the basis of the Income Tax Returns."
Impact and Final Order
Convinced by the accuracy of the income tax filings—which disclosed a gross annual income far exceeding the tribunal’s initial assumption—the Court recomputed the total , applying the standard alongside . The final award was raised to ₹51,24,980.
The High Court dismissed the Insurance Company’s parallel appeal, directing the insurer to pay the balance of ₹37,16,980, along with 7% interest from the date the was filed. This decision confirms that when credible financial evidence is available, judicial bodies must anchor their calculations in that documentation rather than relying on arbitrary estimates, ensuring fairer outcomes for the families of road accident victims.
