The Supreme Court has delivered a significant judgment recognising the immense economic and social contribution of homemakers, describing them as “nation builders” whose work must not be undervalued while determining compensation in motor accident claims.
The bench of Justice Sanjay Karol also expressed serious concern over prolonged delays in the disposal of motor accident compensation cases, observing that such delays defeat the very purpose of welfare-oriented legislation.
An appeal arose from a motor accident claim that has remained pending for nearly twenty-five years. The case concerned the death of a woman homemaker in a road accident that occurred on November 25, 2001, when she was travelling to Fatehabad from Sirsa. The accident was attributed to the rash and negligent driving of the offending vehicle.
Following the accident, the deceased’s legal heirs approached the Motor Accident Claims Tribunal (MACT), Sirsa. In December 2003, the Tribunal awarded compensation of only ₹2.42 lakh. Dissatisfied with the amount, the family filed an appeal before the Punjab and Haryana High Court in 2004 seeking enhancement.
However, the appeal remained pending for nearly twenty years. The High Court eventually enhanced the compensation to ₹8.43 lakh in December 2024 along with interest. Even then, the claimants approached the Supreme Court seeking further enhancement, contending that the compensation still failed to adequately reflect the contribution of the deceased homemaker.
While hearing the matter, the Supreme Court took note of the extraordinary delay in disposal of the appeal. The Court observed that records indicated the case file had been affected by a fire incident in the High Court in 2011, resulting in large-scale destruction and reconstruction of court records. Nevertheless, the Bench questioned why a claim arising under a beneficial legislation remained pending for such a prolonged period.
The Court remarked that delays of this magnitude compound the suffering of families already dealing with the loss of a loved one. It stressed that compensation awarded under motor accident laws is intended to provide “just and fair” relief and should not be frustrated by decades-long litigation.
In a broader observation, the Court noted that excessive delays are not isolated incidents and appear to be a recurring feature in motor accident compensation cases across several High Courts. Referring to numerous decisions decided by the Supreme Court in recent years, the Bench highlighted that appeals in many cases remained pending in High Courts for periods ranging from five to eighteen years.
A central issue before the Court was how the contribution of a homemaker should be valued while computing compensation.
The Bench observed that Indian society often refers to the woman managing a household as the “grihaswamini,” yet courts and society have historically struggled to properly monetise her labour. The judgment emphasised that a homemaker’s work is indispensable to the functioning of the family and contributes significantly to the nation’s social and economic framework.
The Court held that domestic labour performed by homemakers cannot be treated as having no economic value merely because it does not generate a formal salary. Activities such as childcare, elderly care, household management, emotional support, and maintenance of the family unit create substantial economic benefits and therefore deserve meaningful recognition in compensation law.
The Supreme Court noted that courts must adopt a realistic and progressive approach while assessing compensation for the death of homemakers. It observed that undervaluation of domestic labour perpetuates gender-based inequities and fails to recognise the actual contribution made by women within households.
The judgment discusses various judicial precedents and principles for quantifying the services rendered by homemakers and further examines whether “loss of domestic care” should be recognised as a distinct head of compensation. The Court underscored that the value of household services extends beyond simple economic calculations and forms an essential pillar of family welfare.
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