The Supreme Court on Thursday held that the loss of domestic care and household services provided by a homemaker constituted a distinct and compensable head of damages in motor accident compensation cases and quantified the minimum value of such services at Rs 30,000 per month.
The Bench of Justice Sanjay Karol and Justice NK Singh passed the order on an appeal arising out of proceedings under the Motor Vehicles Act. The Court observed that the contribution of homemakers extended far beyond routine household work and played a significant role in the development of families, society, and the nation.
Recognising the economic and social value of unpaid domestic labour, the Court held that the loss suffered by family members due to the death or incapacitation of a homemaker deserved separate consideration while assessing compensation in motor accident claims.
The Bench noted that homemakers performed indispensable caregiving and household management functions that directly contributed to the upbringing of individuals and the overall well-being of families. Such contributions could not be overlooked merely because they did not generate conventional income. Emphasising the importance of this role, the Court described homemakers as nation-builders whose work contributed to human development and social progress.
The Apex Court held that loss of domestic care would constitute an additional and independent head of damages over and above the conventional heads of compensation recognised by the Constitution Bench judgment in National Insurance Company Limited v. Pranay Sethi. It clarified that while determining just compensation under the Motor Vehicles Act, tribunals and courts must separately account for the value of domestic services rendered by a homemaker.
The Court further observed that the expression “homemaker” should be understood in a broader and more meaningful sense, reflecting the substantial contribution made by individuals who dedicate their time and effort to managing households and caring for family members.
The judgment built upon the Supreme Court’s evolving approach towards recognising the economic value of unpaid domestic work. The Bench referred to the Court’s earlier observations in a 2024 decision where it had rejected the notion that homemakers did not work and held that their notional income could not be assessed below the minimum wages prescribed for a daily wage worker. The present ruling has taken the principle further by specifically quantifying the minimum monthly value of domestic care and household services at Rs 30,000.
Apart from addressing compensation principles, the Supreme Court also issued important directions aimed at ensuring the speedy disposal of motor accident compensation claims. Referring to Section 169 of the Motor Vehicles Act, which envisages a summary procedure before Motor Accident Claims Tribunals, the Court observed that the legislative intent behind the provision was to ensure expeditious adjudication of compensation claims and timely relief to victims and their families.
The Bench expressed hope that the statutory framework governing motor accident claims would be implemented in its true spirit and that tribunals would adhere to the summary procedure contemplated under the Act. The Court further observed that delays in adjudication defeat the object of the welfare legislation and undermine access to effective remedies for accident victims.
To strengthen institutional oversight, the Court expressed its expectation that the Chief Justices of all High Courts would monitor the functioning of Motor Accident Claims Tribunals within their respective jurisdictions and ensure the timely disposal of pending cases. It also emphasised the need for effective implementation of the principles laid down in the judgement while determining compensation in future motor accident claims.
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