– This is the script of CNBC's news report for China's CCTV on August 3, Monday.
Welcome to CNBC Business Daily, I'm Qian Chen.
One of the most difficult questions falls in front of airlines and victims' families: how much money is each of the lives lost worth?
One of the most commonly used reference to calculate the compensation amount payable is called the Montreal Convention.
The Montreal Convention was signed in the year of 1999. It requires an airline to pay 113,100 SDRs as a minimum liability regardless of fault.
Today, more than 100 countries have ratified the treaty, and the US, China, Germany, as well as Malaysia are among them.
Therefore, according to the treaty, Germanwings victims' families are guaranteed around $170,000 each.
Besides the minimum liability, an airline is NOT liable for any amount over the minimum if it can prove that the accident was not negligent. However, proving "zero fault" is extremely difficult, according to a report by the Danko Law Firm in California.
Failing to prove "zero fault" would mean that settlements can be unlimited.
However, a few countries, Russia and Indonesia included, have ratified only the older treaty called Warsaw Convention, which was replaced by the Montreal Convention.
The Warsaw Convention was signed in 1929, and has two fundamental differences from the newer one. No.1 - it sets a far lower minimum liability ($8,300), and No. 2 - it says that an airline is not liable for any amount over the minimum if it can prove it took all possible steps to avoid the accident.
Obviously, that's much easier to do.
Among the factors that will affect any settlement amount will be the country where cases are litigated. Settlements are partly determined by the victims' wages, age and life expectancy, all of which differ from country to country.
Take a look at this bar chart - it tells how air crash settlements can vary by victims' nationality.
According to data provided by James Healy-Pratt, head of the aviation department at Stewarts Law in London, the highest average settlements are in the U.S. ($4.5 million), much greater than that of European and Asian countries.
CNBC's Qian Chen, reporting from Singapore.
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