Supreme Court Upholds Compensation for Auto Driver’s Death Due to Cardiac Arrest: C. Manjamma vs. The Divisional Manager (2022)

Date of the Judgment: March 29, 2022
Citation: 2022 INSC 256
Judges: Justice Dinesh Maheshwari and Justice Aniruddha Bose
Can a sudden cardiac arrest during work be considered an employment-related injury, entitling the family to compensation? The Supreme Court of India recently addressed this question in a case involving the death of an auto-rickshaw driver. The court had to determine whether the High Court was right in overturning the Labour Commissioner’s decision, which had granted compensation to the family. The case was decided by a bench of Justice Dinesh Maheshwari and Justice Aniruddha Bose, with Justice Maheshwari authoring the judgment.

Case Background

The case revolves around the death of an auto-rickshaw driver who suffered a cardiac arrest while on duty on April 7, 2010. His wife and mother, the appellants, filed a claim for compensation with the Labour Officer and Commissioner for Workmen’s Compensation, Davanagere (‘the Commissioner’). They argued that the driver’s death was a result of the stress and strain of his job. The Commissioner awarded them compensation, but this decision was later overturned by the High Court of Karnataka.

Timeline:

Course of Proceedings

The Labour Commissioner initially ruled in favor of the appellants, awarding them compensation. The High Court of Karnataka, however, reversed this decision, stating that there was no evidence to establish a direct link between the driver’s death and his occupation. The High Court relied on a previous Supreme Court decision, Shakuntala Chandrakant Shreshti vs Prabhakar Maruti Garvali & Anr. : (2007) 11 SCC 668, to support its conclusion that the claimants had not established the necessary nexus between the death and the employment. The appellants then appealed to the Supreme Court.

Legal Framework

The case is governed by the Employees Compensation Act, 1933. The relevant section is Section 30 of the Employees Compensation Act, 1933, which deals with appeals to the High Court on substantial questions of law. The court also considered the interpretation of what constitutes an injury arising “out of and in the course of employment.”

Section 30 of the Employees Compensation Act, 1933 states:

“30. Appeals.—(1) An appeal shall lie to the High Court from the following orders of a Commissioner, namely:—
(a) an order awarding as compensation a lump sum whether by way of redemption of a half-monthly payment or otherwise or disallowing a claim in full or in part for a lump sum;
(b) an order awarding interest or penalty under section 4A;
(c) an order refusing to allow redemption of a half-monthly payment;
(d) an order providing for the payment of compensation by periodical payments.
(e) an order awarding a sum by way of compensation under section 4(1)(d).
Provided that no appeal shall lie against any order unless a substantial question of law is involved in the appeal and in the case of an order other than an order such as is referred to in clause (b), unless the amount in dispute is not less than one hundred rupees or in the case of an order such as is referred to in clause (b), unless the amount in dispute is not less than ten rupees.”

Arguments

Appellant’s Arguments:

• The appellants argued that the deceased was 30 years old and employed as an auto-rickshaw driver.
• They contended that he died while on duty due to a cardiac arrest, which was a direct result of the stress and strain of his job.
• The Commissioner’s findings were based on evidence such as the FIR, inquest report, spot report, charge sheet, and post-mortem report.
• They asserted that the High Court erred in overturning the Commissioner’s decision, as there was no perversity in the findings of fact.
• They distinguished the case from Shakuntala Chandrakant Shreshti (supra), where the deceased was a cleaner and not subjected to the same level of stress.

Respondent’s Arguments:

• The respondent-insurer argued that the appellants failed to establish that the death occurred due to employment or reasons attributable to it.
• They relied on the Shakuntala Chandrakant Shreshti (supra) case to support their claim that the claimants had not proven the basic jurisdictional facts.
• They contended that the High Court was correct in interfering with the Commissioner’s decision.

Innovativeness of the Argument: The appellant innovatively distinguished the present case from *Shakuntala Chandrakant Shreshti (supra)*, highlighting the difference in job nature and stress levels between a driver and a cleaner.

Issues Framed by the Supreme Court

The Supreme Court did not explicitly frame issues in this judgment. However, the primary issue before the court was:

1. Whether the High Court was justified in overturning the Labour Commissioner’s award of compensation based on the facts and evidence presented.

Treatment of the Issue by the Court:

Authorities

The Court also considered Section 30 of the Employees Compensation Act, 1933, which deals with appeals to the High Court on substantial questions of law.

Judgment

How each authority was viewed by the Court?

• Shakuntala Chandrakant Shreshti vs Prabhakar Maruti Garvali & Anr. : (2007) 11 SCC 668*: The court distinguished this case, noting that the nature of duty in the cited case was that of a cleaner, which is different from that of a driver who is exposed to stress and strain.

What weighed in the mind of the Court?

The Supreme Court was primarily influenced by the factual findings of the Labour Commissioner, who had thoroughly examined the evidence and concluded that the driver’s death was linked to his employment. The court emphasized that the High Court should not have interfered with these findings, especially since no substantial question of law was involved. The court also took into account the nature of the driver’s job, which involved stress and strain, in contrast to the cleaner’s job in the *Shakuntala Chandrakant Shreshti* case.

Logical Reasoning:

The Court’s reasoning was that the Commissioner’s decision was based on a thorough examination of the evidence and that there was no perversity in the findings. The Court emphasized that the High Court should not have interfered with the Commissioner’s decision, especially since no substantial question of law was involved. The court also took into account the nature of the driver’s job, which involved stress and strain, in contrast to the cleaner’s job in the *Shakuntala Chandrakant Shreshti* case. The court noted that the Commissioner’s view was a possible view of the matter in the given set of facts and circumstances.

The Supreme Court stated, “the view as taken by the Commissioner was the one based on the material placed on record, which basically established that the deceased was indeed employed as a driver on the vehicle; he was 30 years of age; and he died while on duty and his demise due to cardiac arrest was attributable to his job of driver.”

The Court also observed, “there had not been shown any other background aspect or any other clinching feature because of which death of the workman, a 30-year-old person, could be attributed to any other cause.”

Further, the Court stated, “the view taken by the Commissioner had been a possible view of the matter in the given set of facts and circumstances; and there was no reason for the High Court to interfere with the same, particularly when the case did not involve any substantial question of law within the meaning of Section 30 of Employees Compensation Act, 1933.”

The Supreme Court did not consider any alternative interpretations of the facts. It focused on whether the High Court was correct in overturning the Commissioner’s decision, and it concluded that the High Court had erred in doing so.

The decision was unanimous, with both judges agreeing that the High Court’s interference was not justified.

The implications of this decision are that it reinforces the principle that if there is a possible view of the matter based on evidence, the High Court should not interfere with the findings of the Commissioner, particularly when no substantial question of law is involved. It also highlights that the nature of a job and its associated stress and strain can be a factor in determining whether a death is employment-related.

Key Takeaways

• ✓ A cardiac arrest suffered by an employee while on duty can be considered an employment-related injury if it is attributable to the nature of the job.
• ✓ High Courts should not interfere with the findings of the Labour Commissioner if those findings are based on evidence and do not involve a substantial question of law.
• ✓ The nature of a job and its associated stress and strain can be a factor in determining whether a death is employment-related.

Directions

The Supreme Court set aside the High Court’s judgment and restored the Labour Commissioner’s award of compensation to the appellants. No costs were awarded.

Development of Law

The ratio decidendi of this case is that the High Court should not interfere with the findings of the Labour Commissioner if those findings are based on evidence and do not involve a substantial question of law. This case reinforces the principle that a death due to cardiac arrest during employment can be considered an employment-related injury if it is attributable to the nature of the job. This is a reiteration of existing law, but it clarifies the application of these principles in cases involving sudden health issues during employment.

Conclusion

The Supreme Court’s decision in C. Manjamma vs. The Divisional Manager reinforces the importance of considering the nature of an employee’s job when determining whether a death is employment-related. The court upheld the Labour Commissioner’s decision, emphasizing that the High Court should not have interfered with a fact-based finding when no substantial question of law was involved. This case provides clarity on the scope of compensation for employees who suffer health issues, such as cardiac arrest, due to the stress and strain of their work.

Category:

Parent Category: Employees Compensation Act, 1933

Child Category: Section 30, Employees Compensation Act, 1933

Parent Category: Labour Law

Child Category: Workmen Compensation

Parent Category: Supreme Court Judgments

Child Category: Compensation Law

FAQ

Q: What is the main issue in this case?
A: The main issue was whether the High Court was right in reversing the Labour Commissioner’s decision to award compensation to the family of an auto-rickshaw driver who died of a cardiac arrest while on duty.

Q: What did the Supreme Court decide?
A: The Supreme Court overturned the High Court’s decision and restored the Labour Commissioner’s award, holding that the driver’s death was employment-related.

Q: What was the reasoning of the Supreme Court?
A: The Supreme Court reasoned that the Labour Commissioner’s decision was based on a thorough examination of the evidence, and there was no perversity in the findings. The court also noted that the stress of the driver’s job could have contributed to the cardiac arrest.

Q: What is the significance of this judgment?
A: This judgment reinforces that sudden health issues during employment can be considered employment-related injuries if they are attributable to the nature of the job. It also clarifies that High Courts should not interfere with the findings of the Labour Commissioner if those findings are based on evidence and do not involve a substantial question of law.

Q: What does this mean for employees?
A: This means that if an employee suffers a health issue, such as a cardiac arrest, during work, their family may be eligible for compensation if the condition is linked to the nature of their job.