‘Homemaker no unskilled worker, takes no leave’: Madhya Pradesh High Court raises payout for kin of woman killed in accident
Even in the absence of strict income proof, the notional value of a homemaker’s services must be assessed realistically and not reduced to bare minimum assumptions, the Madhya Pradesh High Court stated.
7 min readNew DelhiUpdated: Apr 4, 2026 07:48 AM IST
The Madhya Pradesh High Court’s judgment adds to a growing judicial trend recognising unpaid domestic work as an indispensable economic activity. (Image generated using AI)
Madhya Pradesh High Court news: Reaffirming the economic value of unpaid domestic work, the Madhya Pradesh High Court has held that a homemaker’s contribution cannot be equated with that of an unskilled labourer and such “multifarious services” form the backbone of family life, while enhancing the relief in a motor accident case to Rs 5.44 lakh.
Justice Hirdesh was hearing a miscellaneous appeal filed by a family member of a woman who had died in an accident. The appeal was filed under Section 173 of the Motor Vehicles Act, in the wake of an award passed by the Motor Accident Claims Tribunal (MACT), Morena, which had fixed compensation at Rs 4.28 lakh for the homemaker’s death.
“A homemaker renders multifarious services to the family, manages the entire household without fixed working hours and without any leave,” the Madhya Pradesh High Court observed, emphasising that the economic value of such labour “cannot be ignored while determining just compensation.”
With regard to the assessment of income, the claims tribunal assessed the deceased woman’s income at Rs 4,500 per month on the ground that no documentary evidence regarding her income was produced.
However, the record reflects that the deceased, being a woman, was also a homemaker.
The contribution made by a homemaker cannot be equated with that of an unskilled labourer.
The court granted an additional compensation of Rs 1,15,729 to the claimant, along with interest at the same rate as fixed by the tribunal.
It directed that the enhanced amount be paid within three months from receipt of the certified order.
It further directed the appellant to deposit any differential court fees within one month, if applicable, before issuance of the certified copy.
Justice Hirdesh directed that the enhanced amount of Rs 5.4 lakh be paid within three months.
Tribunal’s assessment erroneous
The appellant had challenged the tribunal’s February 7, 2019, award, arguing that the income of the deceased had been assessed on the lower side.
It was submitted that the deceased was engaged in agricultural activities, animal husbandry, and milk selling, earning around Rs 15,000 per month, an aspect that was not adequately considered.
However, the tribunal had pegged her income at Rs 4,500 per month due to lack of documentary proof.
The high court found this approach legally untenable, noting that even in the absence of strict proof of income, the notional value of a homemaker’s services must be assessed realistically and not reduced to bare minimum assumptions.
Correcting the error, the court held that the deceased’s income ought to have been assessed at least at the level of a semi-skilled worker under the Minimum Wages Act, which stood at Rs 7,982 per month at the relevant time.
The court emphasised that homemakers often contribute to multiple income-generating and household activities simultaneously, making their role economically significant despite the absence of formal wage records.
MP High Court: A Homemaker Is Not an Unskilled Labourer — Her Work Has Real Economic Value
"A homemaker renders multifarious services to the family, manages the entire household without fixed working hours and without any leave. The economic value of such labour cannot be ignored while determining just compensation."— Justice Hirdesh, Madhya Pradesh High Court
TRIBUNAL'S VALUATION vs HIGH COURT'S CORRECTION
❌ Tribunal's Assessment📉₹4,500Per MonthEquated with Unskilled LabourTribunal fixed income at bare minimum due to absence of documentary proof — ignoring her agricultural work, animal husbandry and milk selling worth ~Rs 15,000/monthTotal compensation awarded: Rs 4.28 lakh
✅ High Court's Correction📈₹7,982Per MonthReassessed at Semi-Skilled LevelHC applied semi-skilled wage rate under Minimum Wages Act — ruling that no-document cannot mean no-value. Notional income must reflect real contributionTotal compensation enhanced: Rs 5.44 lakh
How HC reached Rs 5.44 lakh: Rs 7,982/month + 10% future prospects → annual income Rs 1,05,362 → less 50% personal expenses → dependency Rs 52,681 × multiplier 9 = Rs 4,74,129 + Rs 40,000 consortium + Rs 30,000 estate & funeral
🏛️ Delhi HC — February 2025In a maintenance case, Delhi HC held that a homemaker does not "sit idle" — her labour enables the earning spouse to function. Denying maintenance by calling her "idle" is "unrealistic and unjust."
SIGNIFICANCETwo High Courts in one month reaffirm: unpaid domestic work is economically indispensable. Absence of formal wages or documents cannot diminish the legal recognition of a homemaker's continuous, multifaceted contribution.
Reassessing the award, the court recalculated compensation under well-established heads to arrive at a just figure.
It first determined the annual income of the deceased at Rs 95,784 (Rs 7,982 per month), treating her at par with a semi-skilled worker.
To this, 10 per cent was added towards future prospects, enhancing the annual income to Rs 1,05,362.
After deducting one-half towards personal expenses, the annual dependency was computed at Rs 52,681.
Applying the multiplier of 9, in accordance with settled principles, the loss of dependency was calculated at Rs 4,74,129.
In addition to the loss of dependency, the court granted compensation under conventional heads, awarding Rs 40,000 towards loss of consortium and Rs 30,000 collectively towards loss of estate and funeral expenses.
On a cumulative assessment, the total compensation was recalculated at Rs 5,44,129.
Advocate Sanjay Singh, counsel for the appellant–claimant, argued that the MACT had erred in assessing the deceased’s income at a meagre Rs 4,500 per month, contending that such a determination failed to reflect her actual economic contribution.
It was submitted that the deceased was not only a homemaker but was also actively engaged in agricultural work, animal husbandry, and the sale of milk, earning nearly Rs 15,000 per month.
The counsel further pointed out that the tribunal had placed undue emphasis on the absence of documentary proof, overlooking the practical realities of rural livelihoods where income is often unrecorded.
It was argued that this approach resulted in a gross undervaluation of the deceased’s contribution to the family.
Additionally, the appellant contended that the tribunal failed to award just and reasonable compensation under other conventional heads, such as loss of estate and funeral expenses.
Applying Supreme Court principles
In recalculating compensation, the court applied settled principles laid down by the Supreme Court.
According to the apex court, an addition of 10 per cent towards future prospects is in line with National Insurance Company Ltd vs Pranay Sethi.
Adoption of multiplier based on age, as per Sarla Verma vs Delhi Transport Corporation.
Award of compensation under conventional heads, such as consortium and estate, following United India Insurance Co Ltd vs Satinder Kaur.
After recalculations, the total compensation was enhanced to Rs 5,44,129 from Rs 4,28,400.
Recognition of invisible labour
The judgment adds to a growing judicial trend recognising unpaid domestic work as an indispensable economic activity.
By explicitly rejecting the classification of homemakers as unskilled workers, the court reaffirmed that compensation law must evolve to reflect the true value of household labour.
The ruling underscores that the absence of formal employment or documentation cannot diminish the legal recognition of the vital, continuous, and multifaceted contributions made by homemakers.
Delhi High Court on homemakers
Last month, while dealing with a case involving grant of maintenance in a matrimonial dispute, the Delhi High Court had observed that the assumption that a non-earning spouse is “idle” reflects a misunderstanding of domestic contribution.
Justice Swarana Kanta Sharma in a detailed judgment passed on February 16 allowed the wife’s plea and set aside the orders of the magistrate and the appellate court under the Protection of Women from Domestic Violence Act (PWDV Act) that had denied her interim maintenance.
On the argument on behalf of the husband that the wife cannot sit “idle” and claim maintenance, the court noted that a homemaker does not “sit idle” but does labour that allows the earning spouse to function effectively.
“A homemaker does not “sit idle”; she performs labour that enables the earning spouse to function effectively. To disregard this contribution while adjudicating claims of maintenance would be unrealistic and unjust,” the order read.
Vineet Upadhyay is an Assistant Editor with The Indian Express, where he leads specialized coverage of the Indian judicial system.
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