Notional income assessment manual workers requires realistic evaluation historical benchmarks periodic adjustments

In the absence of direct documentary proof of employment or fixed monthly earnings, the notional income of self-employed individuals, manual laborers, or coolies in motor accident compensation claims must be evaluated realistically based on established judicial benchmarks with appropriate periodic adjustments. Where historical precedents establish the monthly notional income of a manual laborer at a baseline rate for a given year, tribunals must incorporate nominal incremental adjustments to account for economic changes and wage growth when computing the baseline income for subsequent years. Setting unrealistically low monthly income figures based on outdated statutory schedules without considering market reality or judicial benchmarks constitutes a misapplication of principles governing just compensation. (S. Shakul Hameed v. Tamil Nadu State Transport Corporation Limited | 2026 INSC 29)