Multiplier Method Under Motor Vehicles Act Cannot Be Applied To Electrocution Death Cases : Supreme Court
The Supreme Court recently clarified that the multiplier method used in computing compensation in motor accident claim cases cannot be applied for computing compensation in electrocution death cases. “…the multiplier method cannot be applied to determine compensation in cases of electrocution. Since the calculation paradigm as provided for in connection with the Motor Vehicles Act, 1988...
The Supreme Court recently clarified that the multiplier method used in computing compensation in motor accident claim cases cannot be applied for computing compensation in electrocution death cases.
“…the multiplier method cannot be applied to determine compensation in cases of electrocution. Since the calculation paradigm as provided for in connection with the Motor Vehicles Act, 1988 is dependent on the multiplier, the scenario thereunder could not have been applied mutatis mutandis to electrocution cases, as done by the High Court in the impugned judgment. It is a matter of law that the Electricity Act 2003 does not provide for the method to calculate compensation. What it does provide is the liability of the licensee to pay compensation in certain scenarios under Section 57 thereof but does not say anything regarding the method applicable to calculating the same.”, observed a bench of Justice Sanjay Karol and Justice Nongmeikapam Kotiswar Singh.
Referring to its own judgment of Raman v. Uttar Haryana Bijli Vitran Nigam Ltd. (2014), the Court held that the multiplier method cannot be applied to determine compensation in cases of electrocution.
The judgment arose from two electrocution incidents, including the death of a man who came into contact with an 11 KV transmission line and the severe injury suffered by another person after he came into contact with a 66 KV line while attempting to retrieve a cricket ball.
Writ petitions were filed before the High Court seeking compensation for the death that occurred due to electrocution. The High Court, ignoring the disputed question of facts, has allowed the writ petitions, granting compensation to the claimants, applying the multiplier method on the lines of the Motor Vehicles Act, 1988.
Aggrieved by the High Court's decision, an appeal was preferred before the Supreme Court by the Karnataka Power Transmission Corporation.
Setting aside the High Court's decision, the judgment authored by Justice Karol faulted the High Court for applying the Motor Vehicle Act's multiplier method, despite the same being inapplicable to the Electricity Act, 2003.
Also From Judgment: Electrocution Deaths Attract Strict Liability On Electricity Boards, Not Absolute Liability: Supreme Court
Cause Title: KARNATAKA POWER TRANSMISSION CORPORATION LIMITED VERSUS REKHA & ORS.
Citation : 2026 LiveLaw (SC) 799