Yes. The family of a self-employed accident victim is entitled to the same future-prospects addition that salaried workers get, and the Supreme Court reaffirmed this in 2025. That single addition can lift a motor-accident claim by lakhs of rupees, so no Claims Tribunal should leave it out just because the deceased ran a shop, drove a taxi, or worked for himself.
Here is how the future-prospects addition works on a self-employed claim, shown as a worked calculation.
WORKED CALCULATION - self-employed victim, age 31
Step 1 Notional / proved monthly income Rs 20,000
Step 2 Add future prospects (below 40 = +40%) Rs 20,000 + 40% = Rs 28,000
Step 3 Annual income Rs 28,000 x 12 = Rs 3,36,000
Step 4 Deduct personal expenses (1/4 here) Rs 3,36,000 - 25% = Rs 2,52,000
Step 5 Apply multiplier (age 31 = 16) Rs 2,52,000 x 16 = Rs 40,32,000
-----------------------------------------------------------------
Loss-of-dependency component Rs 40,32,000
+ fixed conventional heads (estate,
funeral, consortium per Pranay Sethi)
Without the Step 2 addition, the same claim would settle at Rs 28,80,000 on dependency. The 40 percent future-prospects uplift adds about Rs 11.5 lakh in this illustration alone. The figures above are an illustration of the method, not the exact sum of any one case.
In Kulwinder Kaur v. Parshant Sharma, 2025 INSC 950 decided on 8 August 2025, the Supreme Court confirmed that a self-employed deceased's dependants are entitled to the future-prospects addition. The Court rejected the older, narrow view that this benefit belonged only to people on a fixed salary, reasoning that a self-employed person is equally bound to grow income over a working life.
The deceased in that case was 31 years old, below the 40-year line, so the Court added 40 percent for future prospects, applying the slab framework from the Constitution Bench in National Insurance Co. Ltd. v. Pranay Sethi, (2017) 16 SCC 680. The 40 percent figure in this 2025 case flows directly from the deceased being under 40; the other age slabs come from Pranay Sethi itself, set out below.
The percentage you add depends on the victim's age. These slabs are settled law from the Constitution Bench in Pranay Sethi (2017), applied to both salaried and self-employed claims.
| Age of victim | Future-prospects addition |
|---|---|
| Below 40 years | 40 percent |
| 40 to 50 years | 25 percent |
| 50 to 60 years | 10 percent |
Only the “below 40, so 40 percent” line was the operative slab in the 2025 Kulwinder Kaur case. The 25 percent and 10 percent slabs are the Pranay Sethi figures for the older age bands.
The addition is not automatic in practice; you must plead it and prove the income base. File these steps so the Tribunal applies the full method.
The same multiplier method and personal-expense deductions are explained in our guide to the motor-accident multiplier method, and the petition mechanics are covered in how to file a MACT petition.
Kashvi Pathak, 34, ran a small tailoring business in Jaipur district and died in a road accident in 2025. Her family proved an income of Rs 25,000 a month through bank statements and GST returns. Because she was below 40, the Tribunal added 40 percent for future prospects, taking the base to Rs 35,000 a month, or Rs 4,20,000 a year. After a one-fourth personal-expense deduction the figure was Rs 3,15,000, and with the age-based multiplier of 16 the loss-of-dependency component came to Rs 50,40,000, before the fixed conventional heads were added. Skipping the future-prospects step would have cost her family more than Rs 14 lakh.
Yes. In Kulwinder Kaur v. Parshant Sharma, 2025 INSC 950, the Supreme Court confirmed that the dependants of a self-employed deceased are entitled to the future-prospects addition, the same as salaried workers, applying the Pranay Sethi framework.
40 percent of the established or notional income, under the Constitution Bench slabs in Pranay Sethi (2017). This was the operative addition in the 2025 Kulwinder Kaur case because the deceased was 31.
Below 40 years gets 40 percent, 40 to 50 years gets 25 percent, and 50 to 60 years gets 10 percent. These slabs come from National Insurance Co. v. Pranay Sethi, (2017) 16 SCC 680.
The Tribunal can fix a fair notional income based on the trade, place, and circumstances, then apply the same future-prospects addition and multiplier. Bring whatever partial proof you have - bank statements, licences, contracts.
Add future prospects to the income first, then deduct personal expenses, then apply the multiplier. The order follows Sarla Verma as approved in Pranay Sethi.
The same age-based multiplier table from Sarla Verma v. DTC applies regardless of employment type. The multiplier depends only on the victim's age, not on whether the income was salaried or self-employed.
It addresses future prospects for the self-employed. The multiplier method and the personal-expense deductions remain governed by Sarla Verma and Pranay Sethi as before.