Rajasthan State Road Transport Corporation v. Danish Khan
Background
Danish Khan's father died in a motor accident while working as a Helper for the Rajasthan State Road Transport Corporation, travelling in a bus belonging to the Corporation. His family received compensation from the Motor Accident Claims Tribunal, but his request for compassionate appointment was rejected under Regulation 4(3), which barred compassionate appointment to dependents who had claimed (or could claim) accident compensation against the Corporation. The Rajasthan High Court struck down Regulation 4(3) as discriminatory and violative of Article 14, holding that dependents of employees killed in Corporation-owned vehicles could not be treated worse than dependents of employees killed in other vehicles. The Corporation appealed.
Decision Breakdown
The Supreme Court held that Regulation 4(3) was not discriminatory. It found a valid classification: dependents of employees who died in Corporation-owned vehicles form a distinct class from dependents of employees who died in vehicles not owned by the Corporation, because in the former case the Corporation itself bears the compensation liability, making it reasonable to deny a second benefit (compassionate appointment) to avoid a double burden on the same employer. The classification had a rational nexus with the Regulation's object of preventing this dual liability. The High Court's judgment was set aside, and the Corporation's appeals were allowed.
Lesson Learnt
A government corporation's internal rule can validly treat employees' families differently depending on who is liable to pay compensation for a death, as long as the distinction is logical and relevant: courts will not strike down such a rule as discriminatory merely because it produces different outcomes for different groups.