Synopsis

In this motor accident claim, the Karnataka High Court addressed two pivotal issues: (i) the liability of a registered owner who claimed prior sale of the vehicle, and (ii) the correct method of computing compensation based on income tax returns. The court held that the registered owner remains liable unless the transfer of ownership is reflected in the registration certificate, as mere production of an unregistered sale document is insufficient. On compensation, the court ruled that when the deceased’s income tax returns show a gradual increase, the return nearest to the date of the accident should be taken as the basis for computing loss of dependency, rather than averaging multiple years. Consequently, the compensation was enhanced from Rs.33,07,940/- to Rs.47,15,100/-, with 25% future prospects and a 10% escalation on conventional heads as per Pranay Sethi. The liability was fixed solely on the registered owner.

Citation: Sri Sunil Kumar V. v. G. Bhuvaneshwari & Ors., MFA No. 1479 of 2025 with connected matters, decided on 10.03.2026 (Karnataka High Court - DB)
Coram: Hon'ble Mr. Justice S.G. Pandit and Hon'ble Mr. Justice K.V. Aravind (Division Bench)
Core Law: Motor Vehicles Act, 1988 (Sections 166, 168, 173).

1.  Heading for the judgment

Karnataka High Court holds that registered owner of vehicle remains liable despite claimed sale unless transfer of ownership is reflected in registration certificate; while computing loss of dependency based on income tax returns, the nearest return to the date of accident with a gradual increase is to be taken, not the average.

2. Legal framework

This judgment deals with the determination of liability in motor accident claims and the methodology for computing compensation based on income tax returns.

• Motor Vehicles Act, 1988:
  Section 166: Filing of claim petition.
  Section 168: Duty of Tribunal to award just compensation.
  Section 173: Appeals against awards.

• Key Precedents Relied Upon:
  Brij Bihari Gupta v. Manmeet & Ors., 2025 SCC On

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