Kuldeep Singh v. Panna Lal & Anr.
Background
An employee was injured in the course of his work and claimed compensation under the Workmen's Compensation Act. The employer said it had agreed to pay Rs 1.5 lakh in settlement, but that settlement was never registered as the Act requires. The Commissioner ordered the employer to pay Rs 1,31,971 with interest, and the High Court set that order aside on the basis of the settlement.
Decision Breakdown
The Supreme Court allowed the employee's appeal. It held that the High Court overlooked Section 29 of the Act, which requires a settlement to be registered. Because the settlement was not registered, neither the High Court nor any other authority could rely on it. The Court therefore restored the Commissioner's order, including the award and interest.
Lesson Learnt
A private settlement under workers' compensation law does not override the statutory award unless it has been registered as the law requires. Workers should make sure that any settlement offered by an employer is properly registered before they accept it.