Supreme Court: The multiplier method as laid down under Motor Vehicle Act cannot be applied to determine compensation in cases of electrocution

On the question of yardstick of compensation, we find this Court to have observed in a two-Judge Bench decision in Raman v. Uttar Haryana Bijli Vitran Nigam Ltd.   MANU/SC/1204/2014 : 2014:INSC:885 : (2014) 15 SCC 1, that 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. This holding in Raman (supra) relies on Balram Prasad v. Kunal Saha   MANU/SC/1098/2013 : 2013:INSC:717 : (2014) 1 SCC 384. Be that as it may, the overarching principle of just and reasonable, fair compensation would govern the calculation here as well, based on the income of the person and other related claims. {Para 15}

IN THE SUPREME COURT OF INDIA

Civil Appeal No. 10659 of 2026 

Karnataka Power Transmission Corporation Limited Vs. Rekha and Ors.

Hon'ble Judges/Coram:

Sanjay Karol and N. Kotiswar Singh, JJ.

Author: Sanjay Karol, J.

Citation: 2026 INSC 847,MANU/SC/0863/2026

Decided On: 12.08.2026.

Read full judgment here: Click here.

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Supreme Court: Electrocution Deaths Attract Strict Liability On Electricity Boards, Not Absolute Liability

 The High Court had, in effect, held the disputed facts to not be of much relevance because, according to it, it is the standard of absolute liability that is applicable and not strict liability. Since absolute liability obviously has no exceptions, the presence of disputed facts, if at all, would not absolve the Appellant herein. In deciding the correctness of this finding, we must then go to the meaning of absolute liability and strict liability. {Para 10}

11. Absolute liability, as the name itself suggests, is a kind of liability that leaves no scope for exception from such liability. To put it simply, the person who has been deemed to be absolutely liable shall be so liable irrespective of the facts and circumstances in which such imputation has been made upon them. It is applied only to enterprises and comes into play when the activity in which the enterprise is engaged, is inherently dangerous or hazardous and someone has been harmed as a result of the accident that has taken place in performing such activity.

14. Now the question is whether in cases such as these i.e. electrocution of an individual, the standard of liability upon bodies such as the Appellant is strict or absolute. We are of the considered view that to impose strict liability would be more appropriate, for not in all cases can it be said that the electricity boards are liable. The transmission of electricity is undoubtedly inherently dangerous. Those who carry out the inherently dangerous activity should bear the burden, and the State is no exception to that rule. Such enterprises operate on a loss distribution mechanism i.e. they are in the best position to spread the loss incurred through insurance or higher prices, as the case may be. It can also be said that they are expected to factor in these possibilities. It is for these reasons that they are liable to compensate the injured/deceased irrespective of any fault on their part, provided that none of the exceptions to the Rule of strict liability apply to the case at hand. Granted that they would have taken all reasonable care to protect individuals from electrocution. We are supported in this view by the observations made in Prabhakaran Vijaya Kumar, where it has been categorically held that the Rule in Rylands (supra) applies to a number of different categories of cases inter alia, electricity also.

IN THE SUPREME COURT OF INDIA

Civil Appeal No. 10659 of 2026 

Karnataka Power Transmission Corporation Limited Vs. Rekha and Ors.

Hon'ble Judges/Coram:

Sanjay Karol and N. Kotiswar Singh, JJ.

Author: Sanjay Karol, J.

Citation: 2026 INSC 847,MANU/SC/0863/2026

Decided On: 12.08.2026

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Questions and answers on law Part 35

 

Q  :- Whether court can determine compensation in case of death by electrocution relying on provisions of Motor vehicle Act?

Ans: There is no codified law for arriving at the quantum of compensation in cases of this type. The enactments like Motor Vehicles Act, 1988; Workmen Compensation Act, 1948; and Fatal Accidents Act, 1855 may be applied for arriving at the just compensation. 

Madras High Court

Mrs.Saroja vs The Government Of Tamil Nadu on 13 February, 2014

Citation;2014(4)T.A.C 558 Madras

https://bit.ly/3AjtwXn

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Whether court can deviate from following multiplier method to award just compensation to victim in case of electrocution?

The learned Single Judge of the High Court has awarded compensation keeping all these aspects of the matter and has applied the guiding principle of multiplier method after adverting to the case of Sarla Verma & Ors. v. Delhi Transport Corporation & Anr[6]. for the purpose of computation of just and reasonable compensation in favour of the appellant which method should not have been applied to the case on hand, particularly, having regard to the statutory negligence on the part of the respondents in not providing the safety measures to see that live electric wires should not fall on the roof of the building by strictly following the Rules to protect the lives of the public in the residential area. This Court in the case of Dr. Balram Prasad v. Kunal Saha[7], has deviated from following the multiplier method to award just and reasonable compensation in favour of the claimant in a medical negligence case. The same principle will hold good in the case on hand too. 

Supreme Court of India

Raman vs Uttar Haryana Bijli Vitran Nigam ... on 17 December, 2014

Bench: V. Gopala Gowda, C. Nagappan

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Whether court can determine compensation in case of death by electrocution relying on provisions of Motor vehicle Act?

There is no codified law for arriving at the quantum of compensation in cases of this type. The enactments like Motor Vehicles Act, 1988; Workmen Compensation Act, 1948; and Fatal Accidents Act, 1855 may be applied for arriving at the just compensation. In the decision reported in (1969) 3 SCC 64 (C.K.Subramania Iyer v. T.Kunhikuttan Nair) the Supreme Courtheld that there is no exact uniform rule for measuring the value of human life and the measure of damages cannot be arrived at precisely. In the decision reported in (2001) 8 SCC 151 (M.S.Grewal v. Deep Chand Sood) the Supreme Court held that multiplier method may be adopted to arrive at the just compensation. The age of the deceased can also be taken for arriving at a correct multiplier as per the judgment of the Supreme Court reported in 2011 (5) LW 408(P.S.Somanathan & Others v. District Insurance Officer & Another).

Madras High Court

Mrs.Saroja vs The Government Of Tamil Nadu on 13 February, 2014

Citation;2014(4)T.A.C 558 Madras

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Leading Judgment on liability to pay compensation by electricity company in electrocution cases.

 The learned Single Judge of the High Court adverted to Section 68 of the Indian Electricity Act, 2003 (for short "the Act") and Rule 91 of the Electricity Rules, 1956 (for short "the Rules") which lay down the procedure of safety and protective devices to be provided for overhead electric lines erected over any part of the street or public place or any consumer's premises and mandate that those shall be protected with a device approved by the Inspector for rendering the line electrically harmless in case it breaks.

 The learned Single Judge of the High Court further referred to Rules 29, 44 and 46 of the Rules which are statutory in nature which require the electricity authorities to conduct periodical inspection of the lines maintained by them and to take all such safety measures to prevent accident and maintain the lines in such a manner that life and property of the general public is protected. The learned Single Judge has considered the position of law declared by this Court in catena of cases for awarding compensation, particularly, the electrocution cases, and held the principle of "strict liability" and consequential negligence in awarding compensation in favour of the claimant against the State Electricity Board. This Court and the various High Courts such as High Courts of Madras, Madhya Pradesh, Orissa, Kerala and Gujarat have awarded compensation to the victims of electrocution in exercise of the extraordinary and appellate jurisdiction, and have held that the Electricity Board Supply Companies are duty bound to take precautionary measures under the provisions of the Act. Therefore, the learned Single Judge has held the electricity authority - the first respondent to be liable to pay the compensation to the claimant irrespective of the fact that the harm could have been avoided by the consumer by taking precautionary measures. 

Supreme Court of India

Raman vs Uttar Haryana Bijli Vitran Nigam ... on 17 December, 2014

Bench: V. Gopala Gowda, C. Nagappan

REPORTABLE

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