The story so far: The High Court of Karnataka, in a judgment arising out of a motor accident compensation dispute with Karnataka State Road Transport Corporation (KSRTC) in a 2013 bus accident, has said that “Any individual who tirelessly strives, showers unconditional love, sacrifices personal comfort at times and ultimately becomes a pillar for happy and stable family is a homemaker.”
What was the case about?
The case arose out of a motor vehicle accident in 2013. The claimant suffered injuries and the Motor Accident Claims Tribunal in Bengaluru awarded her ₹4.55 lakh in compensation. Both the claimant and the KSRTC appealed against the decision. The claimant is an educated woman with a Master’s in Biotechnology and had previously worked as a guest lecturer. But there was no evidence that she was employed when the accident occurred.
The KSRTC argued that having such a higher educational qualification, she cannot be regarded as a homemaker. The claimant submitted that the disability, which is permanent in nature, had affected her ability to perform her responsibilities and that fact should be considered while determining compensation.
What did the court say?
The court observed that every woman who renders services to her family members at home is liable to be regarded as a “homemaker” irrespective of the fact that she holds higher a qualification, let it be a degree, postgraduate degree or a doctorate.
In the opinion of the court, even a working woman or a professional can be considered a home maker so long as such woman renders services at home taking care and looking after the welfare of the family members.
To consider a woman “homemaker”, it is not necessary to project or establish that she is illiterate or she stays at home or that she attends only household work and nothing more.
Any individual who tirelessly strives, showers unconditional love, sacrifices personal comfort at times and ultimately becomes the pillar for a happy and stable family is a homemaker. These qualities are illustrative but not exhaustive.
The court noted that the word ‘homemaker’ is gender-neutral. A homemaker thus can be male or female. It also covers working person or bread winner or wage earner. Therefore, the court held that the claimant in this case can well be considered a home maker.
The court took her notional income as ₹8,000 per month, based on the notional income fixed by the Karnataka State Legal Services Authority for the relevant period.
The court enhanced the compensation by ₹1,96,800 which is ₹1,72,800 towards future financial loss arising from her permanent disability and ₹24,000 for the three months during which she was unable to perform her household responsibilities.
What do earlier judgments say?
Earlier this June 2026, the Supreme court in the matter of Shishu Pal @ Shish Ram & Ors. v. Surjeet & Ors, held that homemakers are the true “nation builders”, whose often invisible and undervalued domestic labour forms the foundation upon which families, professionals, workers, and society at large function and contribute to the nation’s progress.
To standardise this recognition, the court has observed that in motor accident claims involving the death of a homemaker, a separate, substantive head of “loss of domestic care” must be mandatorily factored into the final computation of compensation.
As the court recognised all the aspects of being a homemaker and the unpaid labour that a homemaker undertakes, it directed the Motor Accidents Claim Tribunal (MACT) to award a separate compensation of ₹30,000 per month under the head of “domestic care” in cases involving the death of a homemaker.
However, the Supreme Court has said that “As a result on one circumstance or another, sometimes unfortunate sometimes not, a man may too need to don the role of a homemaker. It is not to take away from the efforts of these men who also deserve recognition and acknowledgment, but for the purposes of the present case and more particularly the quantification of domestic efforts, we limit its application to the quintessential and traditional image, that of a woman.”
In the case of Kirti & Anr. v. Oriental Insurance Company Ltd. (2021), the Supreme Court ruled that any compensation awarded by a court ought to be just, reasonable and consequently must undoubtedly be guided by the principles of fairness, equity, and good conscience. It was relied on in the case dealing with the calculating of notional income of an injured homemaker in the case of Uma Rani Thr Spa Pankaj Thakur v Simranjeet Singh & Ors(2026) by the Delhi High Court.
In that case, the Delhi High Court enhanced the compensation awarded to a homemaker who suffered permanent disability in a motor accident, holding that the tribunal had substantially undervalued both her notional income and the impact of her disability. The court observed that in the absence of documentary proof regarding educational qualifications, minimum wages should be used as a yardstick and the courts should not be constrained to consider wages from the lowest tier.
In that case, the court observed that ascertainment of the effect of the permanent disability on the actual earning capacity involves three steps. The tribunal has to first ascertain what activities the claimant could carry on in spite of the permanent disability and what he could not do as a result of the permanent disability. The second step is to ascertain his avocation, profession and nature of work before the accident, as also his age, and the third step is to find out whether the claimant is totally disabled from earning any kind of livelihood.
While the Supreme Court has recognised the economic value of homemaking, its ₹30,000 benchmark in Shishu Pal was prescribed in the context of the death of a homemaker. The Karnataka High Court’s judgment is significant because it deals with an injured homemaker and considers both her permanent disability and her temporary inability to perform household responsibilities.
Published – August 20, 2026 02:53 pm IST
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