Employees Compensation Act | Death Due To Cardiac Arrest During Employment Is An 'Accident' Arising Out Of Stress And Strain Of Duty: J&K High Court

"The driver felt unconscious while on duty. The Supreme Court held that even if death had not occurred on account of any accident in the popular sense, long spells of driving were a material contributory factor, if not sole cause, accelerated unexpected death at a young age." High Court of Jammu & Kashmir and Ladakh has reaffirmed that the death of an employee due to cardiac arrest during the course of employment constitutes an "accident" under the Employees Compensation Act, 1923, provided a causal nexus is established between the occupational stress and the fatality.

A bench of Justice Shahzad Azeem held that when the nature of duties, such as long-distance tanker driving, contributes to physical strain, such death is clearly attributable to the employer’s trade and business.

The matter arose from a claim petition filed by the dependents of a deceased tanker driver who suffered a fatal cardiac arrest at Pampore while returning from a trip to Kashmir. The insurance company contested the claim, arguing that the death was a natural biological event and lacked the necessary proximity to employment to be classified as an accident. The Assistant Labour Commissioner had initially awarded compensation, prompting the insurer to appeal before the High Court.

The primary legal issue was whether a death caused by cardiac arrest during the course of employment could be legally classified as an "accident arising out of and in the course of employment" under the Act. The court was further tasked with determining whether the claimant had successfully established a nexus between the deceased's specific working conditions—characterized by prolonged driving—and the resultant heart failure.

Employment Nexus And Evidentiary Burden

The Court noted that the claimants provided consistent testimony regarding the long-haul nature of the deceased's duties and the subsequent physical exhaustion. By failing to lead any evidence to rebut these claims, the insurer failed to substantiate its defense of policy violation. The Court emphasized that when the claimants prove that the deceased was actively engaged in the employer’s business at the time of the incident, the evidentiary burden shifts to the insurer to prove otherwise.

Court Explains Doctrine Of Occupational Stress

The Court rejected the insurer’s reliance on Shakuntala Chandrakant Shresti, distinguishing it on the basis that the claimants in the present case had adequately pleaded and proved the stress-related nature of the employment. The bench observed that the testimony of the cleaner/conductor and the family members remained unimpeached, confirming the nexus between the deceased's duty cycle and his cardiac event.

Precedent Value Of Judicial Interpretation

The Court relied heavily on the Supreme Court’s dicta in Param Pal Singh v. National Insurance Co. and Smt. Dariyao Kanwar v. United India Insurance Co., which established that long spells of driving are a material contributory factor in accelerating death by cardiac arrest. These precedents clarify that the term "accident" is not confined to external trauma but encompasses physiological breakdowns directly caused by the rigors of professional duties.

Final Determination On Insurer’s Liability

Concluding that the findings of the Assistant Labour Commissioner were neither perverse nor contrary to settled law, the High Court upheld the award of compensation. The Court held that since the employment-related stress was the triggering factor for the cardiac arrest, the insurance company remains liable to indemnify the employer. The appeal was subsequently dismissed for lacking any substantial question of law.

Date of Decision: 28 September 2026