The court determined that for calculating compensation in cases involving the death of minors, a multiplier of 18 is applicable, aligning with established precedents.

JUDGMENT :

ANISH DAYAL, J.

1. This appeal has been filed assailing the award dated 25^th October 2025 passed by Motor Accidents Claims Tribunal [‘MACT’], South-West District, Dwarka Courts in MACT No.733/2023 seeking enhancement of compensation awarded as Rs. 13,50,260/- at an interest of 7.5% p.a.

2. The incident relates to an accident which occurred on 13^th July 2018, wherein one Kunal Ram/deceased, aged ten years, while riding a bicycle along with his younger brother in Madhepura, Bihar, was hit by a tractor coming from the wrong side. The deceased was rushed to Primary Health Centre, Singheshwar by villagers but was declared 'brought dead' and postmortem report of deceased was prepared recording cause of death as - ‘CR failure due to neurogenic shock as a result of trauma (injuries) caused by hard, blunt & heavy substance.’

3. On 07^th January 2026, this Court had recorded the broad submissions of parties in this case. Time had been granted to counsel for respondent no.3/Insurance Company to revert on the submissions made regarding issue of multiplier for victims below the age of 15 years of age.

4. As regards this issue, factor of ‘18’ has been adopted by the Coordinate Bench of this Court inNational Insurance Co. Ltd. v. Sanju & Ors. inMAC.APP.30/2025 and other connected appeals [MAC.APP.39/2025, MAC.APP.40/2025, MAC.APP.751/2025 and MAC.APP.80/2025] where earlier decisions ofKajal v. Jagdish Chand (2020) 4 SCC 413 ,Master Ayush v. Branch Manager, Reliance General Insurance Co. Ltd. (2022) 7 SCC 738 ,Baby Sakshi Greola v. Manzoor Ahmad Simon 2024 SCC OnLine SC 3692, Karuna Parmar v. Prakash Sinha 2025 INSC 1244 have been referred and assessed in detail.

5. Further, reliance has been placed upon decisions by this Court in National Insurance Co. Ltd. v. Pooja 2025 SCC OnLine Del 1044, Rakesh Sharma v. Ashok 2025 SCC OnLine Del 1364 andCholamandalam MS General Insurance Co. Ltd. v. Bhupan Paswan 2025 SCC OnLine Del 1045, wherein a multiplier of 18 was adopted after considering the decisions of the Supreme Court.

6. The relevant observations made by this Court in Sanju (supra) are extracted as under:

“26. In my view, the argument, at least before this Court, is foreclosed by the judgments in Pooja, Rakesh Sharma, and Bhupan Paswan, where the multiplier 18 has been adopted after considering the judgments in Sarla Verma, Kajal, Master Ayush, and Sakshi Greola. The discussion on this aspect in Bhupan Paswan reads as follows:

“31. The learned Tribunal has computed the compensation by applying a multiplier of 15, by considering the age of the deceased.

32. The calculation of Multiplier has been laid down in the case of Sarla Varma (Supra) as under:-

“21. We therefore hold that the multiplier to be used should be as mentioned in column (4) of the Table above (prepared by applying Susamma Thomas, Trilok Chandra and Charlie), which starts with an operative multiplier of 18 (for the age groups of 15 to 20 and 21 to 25 years), reduced by one unit for every five years, that is M-17 for 26 to 30 years, M-16 for 31 to 35 years, M-15 for 36 to 40 years, M-14 for 41 to 45 years, and M-13 for 46 to 50 years, then reduced by two units for every five years, that is, M-11 for 51 to 55 years, M-9 for 56 to 60 years, M-7 for 61 to 65 years and M-5 for 66 to 70 years.”

33. Evidently, the Judgment is silent on the multiplier to be used for the victims under 15 years of age. This incongruity in the matter of selection of multiplier in the case of persons in the age group up to 15 years was noted in by the Apex the case of Divya vs. National Insurance Company Ltd., Civil Appeal No. 7605/2022.

34. In the most recent judgment of the Supreme Court in Baby Sakshi Greola vs. Manzoor A