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C. Manjamma & Anr. vs The Divisional Manager, The New India Assurance Co. Ltd.

Civil Appeal · 2022 INSC 365Decided 29 Mar 2022
Civil Appeal No. 2568 of 2022
Dinesh Maheshwari · Aniruddha Bose

Background

A driver of an auto-rickshaw died of cardiac arrest while on duty, and his wife and mother claimed compensation before the Labour Officer and Commissioner for Workmen's Compensation, Davanagere, who awarded them about Rs. 4.16 lakh with interest, relying on the FIR, inquest and post-mortem records. The insurer appealed, and the Karnataka High Court reversed the award, holding there was no evidence linking the death to the strain of driving and that the Commissioner lacked jurisdiction to award compensation. The claimants then appealed to the Supreme Court.

Decision Breakdown

The Supreme Court held that the High Court was wrong to interfere, because the Commissioner's finding, that the 30-year-old driver's cardiac arrest was caused by the strain of his job, was a possible view based on the documentary evidence on record (FIR, inquest mahazar, post-mortem and FSL reports), and was not perverse or unsupported by evidence. The Court explained that under Section 30 of the Employees' Compensation Act, a High Court can only interfere on a "substantial question of law," which arises only when a finding is perverse or entirely without legal evidence, not merely because the High Court would have assessed the same evidence differently. Distinguishing the precedent the insurer relied on (which involved a cleaner, not a driver, and different facts), the Court restored the Commissioner's original compensation award in full.

Lesson Learnt

A workman's compensation claim, once supported by cogent documentary evidence and accepted by the fact-finding Commissioner, cannot be overturned by a higher court simply by re-weighing the same evidence: appellate interference in compensation cases is limited to genuine errors of law, not disagreement on facts.

Official source (sci.gov.in)View Judgment (PDF)

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