Rajasthan High Court enhances compensation to ₹78 lakh in a 2015 accident death of a final year MBBS student. Court fixed ₹50,000 notional income recognising the future earning potential of a young doctor and rejecting the argument that a student had no income. A significant judgment in motor accident compensation law.
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In a significant judgment delivered on 18 February 2026, the Rajasthan High Court enhanced compensation to ₹78,30,000 in favour of the family of a 23 year old final year MBBS student who lost his life in a road accident in 2015. The case, titled Smt. Imrawati Devi & Ors. v. Ramveer & Ors. (2026:RJ-JP:7753), reflects an evolving judicial approach that recognises the real earning potential of professional students rather than treating them as non earning individuals at the time of death.
As recorded in the judgment, the deceased Sandeep Kumar, aged 23 years, was a final year MBBS student. He was riding a motorcycle bearing registration number RJ-14-KS-9728 along with his friend when a pickup jeep bearing registration number RJ-18-GA-9574, driven in a rash and negligent manner, caused the accident. He sustained multiple injuries and subsequently died. His parents and siblings filed Claim Petition No. 181 of 2016 before the Motor Accident Claims Tribunal No. 2, Jaipur Metropolitan. The Tribunal awarded compensation of ₹40,90,000, following which both the claimants and the insurance company filed cross appeals on the question of quantum.
The principal issue before the High Court was whether a final year MBBS student, who was not earning at the time of death, could be assigned a substantial notional income based on his future professional prospects. The insurance company argued that the deceased was merely a student and had not earned a single penny, and therefore the Tribunal erred in hypothetically assuming future income. The claimants, on the other hand, contended that the deceased was on the verge of completing his medical degree and would certainly have become a doctor, earning a respectable and stable income.
Justice Anoop Kumar Dhand relied heavily on the Supreme Court decision in Bishnupriya Panda v. Basanti Manjari Mohanty, where the Apex Court dealt with the death of a fourth year MBBS student in a 2013 accident. In that case, the Supreme Court accepted a notional income of ₹50,000 per month and added 40 percent towards future prospects. The Rajasthan High Court observed that the issue had already been settled by the Apex Court and that it had no option but to follow the same reasoning, especially since the present accident had occurred in 2015.
The High Court held that it would be unrealistic and unjust to treat a final year MBBS student as equivalent to a skilled labourer earning minimum wages. Recognising the professional trajectory and high employability associated with an MBBS degree, the Court fixed the notional monthly income of the deceased at ₹50,000. In accordance with the principle laid down in Pranay Sethi, 40 percent was added towards future prospects, amounting to ₹20,000. Thus, the total monthly income was assessed at ₹70,000.
The annual income was calculated at ₹8,40,000 by multiplying ₹70,000 by twelve. Since the deceased was 23 years old, the Court applied multiplier 18 as prescribed under the Supreme Court judgment in Sarla Verma v. Delhi Transport Corporation, which provides a structured multiplier table based on age. The total income over the multiplier period thus came to ₹1,51,20,000. Because the deceased was unmarried, 50 percent was deducted towards personal and living expenses, leaving a loss of dependency amounting to ₹75,60,000.
In addition to loss of dependency, the Court awarded compensation under conventional heads. Loss of consortium was calculated at ₹40,000 each for six claimants, totalling ₹2,40,000. A sum of ₹15,000 was awarded towards loss of estate and another ₹15,000 towards funeral expenses. These amounts brought the total compensation to ₹78,30,000.
Since the Tribunal had originally awarded ₹40,90,000, the High Court enhanced the compensation by ₹37,40,000. The Court also directed that the enhanced amount be deposited within four weeks with interest at 6 percent per annum from the date of filing of the claim petition.
This judgment is important not merely for the quantum of compensation but for the principle it reinforces. The Court clearly recognised that professional students cannot be treated as having zero economic value merely because they had not yet started earning. An MBBS student in the final year stands on the threshold of entering a respected and remunerative profession. Ignoring that trajectory would amount to gross underestimation of earning potential and injustice to the dependents.
The Rajasthan High Court’s decision represents a progressive and realistic approach to motor accident compensation law. By applying established Supreme Court precedents and acknowledging the future prospects of a medical student, the Court ensured that compensation reflected the loss of a promising professional career rather than the temporary status of being a student. The judgment underscores an important legal message: in assessing compensation, courts must account not only for present income but also for the future that was unjustly taken away.
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