In motor accident claims involving death, future prospects of advancement in career or income may be factored into the multiplicand by making an addition to the actual income/salary of the deceased at the time of death (less tax, if applicable). (!) [12000300150009]

A standardized rule of thumb applies: an addition of 50% to the actual salary where the deceased had a permanent job and was below 40 years of age; 30% addition if aged 40-50 years; and no addition if above 50 years. This avoids varying yardsticks or methods. Where the deceased was self-employed or on fixed salary without increments, only actual income is taken, absent exceptional circumstances. [12000300150010]

Actual pay revisions or increments occurring after death (e.g., during pendency of proceedings) cannot be used to inflate the income estimate, as this would unfairly reward delays in litigation and ignore life's imponderables (e.g., possible earlier death, job loss). Courts assess based on evidence available proximate to the accident date. [12000300150022]

In the present case (deceased aged 38 years in permanent job), averaging actual salary (Rs.4,004 pm) with a doubled figure (Rs.8,008 pm) at retirement—equating to a 50% addition yielding Rs.6,006 pm—was approved as conforming to the principle. [12000300150021]