The Supreme Court in Rahul Sharma Vs. National Insurance Co. Ltd., dated 07.05.21 reiterated that “This Court in a Five Judge Bench decision in National Insurance Co. Ltd. Vs. Pranay Sethi (2017) 16 SCC 680, clearly held that in case the deceased is self-employed and below the age of 40, 40% addition would be made to their income as future prospects. In the present case, the deceased was self-employed and was 37 years old, therefore, warranting the addition of 40% towards future prospects. Moreover, Pranay Sethi (supra), affirming the ratio in Sarla Verma held that the deduction towards personal and living expenses for a person such as the deceased who was married with two dependants, to be one-third (1/3rd). Since, the High Court in the impugned judgment deducted 50% the same merits interference by this court.
