Supreme Court Restores Compensation for Driver’s Death in Workmen's Compensation Case

The Supreme Court of India, in its judgment dated March 29, 2022, ruled on the case of C. Manjamma & Another vs The Divisional Manager, New India Assurance Co. Ltd.. The case involved a dispute over workmen’s compensation, where the Karnataka High Court had reversed an earlier compensation award granted to the dependents of a deceased autorickshaw driver. The Supreme Court set aside the High Court’s ruling and restored the compensation originally awarded.

Background of the Case

The case arose from the death of an autorickshaw driver, who allegedly suffered a cardiac arrest while on duty on April 7, 2010. His wife and mother, the appellants in this case, sought compensation under the Workmen’s Compensation Act, 1923. The Labour Officer and Commissioner for Workmen’s Compensation, Davanagere, awarded them a compensation of Rs. 4,15,960/- with 12% annual interest, holding the insurance company liable for the payment.

The insurance company, New India Assurance Co. Ltd., challenged this award before the Karnataka High Court. The High Court reversed the award, ruling that there was insufficient evidence to establish a direct link between the driver’s death and his employment duties. Aggrieved by this decision, the appellants approached the Supreme Court.

Petitioner’s Arguments (C. Manjamma & Another)

The appellants argued:

The deceased was 30 years old and employed as a driver on an autorickshaw at the time of his death.
His death was directly linked to stress and strain from his job.
The Commissioner had based its findings on strong documentary evidence, including the FIR, post-mortem report, inquest report, and witness statements.
The High Court had wrongly re-evaluated the evidence and overturned the award without proper justification.
There was no other medical history that could explain the driver’s cardiac arrest.

Respondent’s Arguments (New India Assurance Co. Ltd.)

The insurance company countered:

The claimants failed to establish that the driver’s death was directly caused by his employment.
There was no clear evidence that the strain of driving led to cardiac arrest.
The High Court had correctly applied the principles laid down in Shakuntala Chandrakant Shreshti vs Prabhakar Maruti Garvali (2007) 11 SCC 668, which required proof of a direct connection between employment and death.

Supreme Court’s Observations

The Supreme Court, comprising Justices Dinesh Maheshwari and Aniruddha Bose, ruled in favor of the appellants and restored the compensation.

On the Findings of the Commissioner

The Court noted:

“The Commissioner had returned the basic findings of fact with reference to the material placed on record. The findings were based on cogent evidence, including the FIR, inquest report, and post-mortem report.”

On the High Court’s Reversal

The Court held:

“There was no substantial question of law involved in the matter for which the High Court could have interfered with the Commissioner’s award.”

The High Court’s observations were found to be assumptive rather than based on evidence. The Supreme Court ruled that the Commissioner had taken a possible and reasonable view, which should not have been disturbed.

On the Application of Precedent

The Court distinguished the present case from the Shakuntala Chandrakant Shreshti judgment, stating:

“The deceased in that case was a cleaner, whereas in the present case, the deceased was a driver. The nature of work was different, and the Commissioner had rightly considered the employment-related strain in this case.”

Final Verdict

The Supreme Court ruled:

The appeal is allowed.
The Karnataka High Court’s decision dated November 15, 2018, is set aside.
The compensation awarded by the Labour Officer and Commissioner for Workmen’s Compensation, Davanagere, is restored.
The insurance company is directed to pay Rs. 4,15,960/- with interest at 12% per annum to the claimants.

Implications of the Judgment

This ruling establishes several key legal principles:

High Courts should not interfere with fact-based findings of the Commissioner unless a substantial question of law is involved.
Employment-related stress can be a valid factor in determining compensation for work-related deaths.
Courts must recognize that physical exertion in jobs like driving can contribute to medical conditions, even without a history of illness.
The Supreme Court reaffirmed that documentary evidence (FIR, post-mortem reports) holds significant value in compensation claims.

Conclusion

The Supreme Court’s ruling in C. Manjamma vs. New India Assurance Co. Ltd. reaffirms the importance of protecting workers’ rights and ensuring fair compensation for work-related deaths. The judgment highlights the need for courts to respect reasoned findings of fact made by statutory authorities and prevents unjustified interference in compensation cases.

Petitioner Name: C. Manjamma & Another.
Respondent Name: The Divisional Manager, New India Assurance Co. Ltd..
Judgment By: Justice Dinesh Maheshwari, Justice Aniruddha Bose.
Place Of Incident: Karnataka.
Judgment Date: 29-03-2022.

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