Murder By Unknown Assailants Is Not 'Accidental Death' Under Mukhymantri Kisan Bima Yojna: Allahabad High Court

"Murder or an incident of like nature as is narrated in the present facts and circumstances, is not an accident as envisaged under the Mukhymantri Yojna for availing compensation," Allahabad High Court, in a significant ruling, held that a death resulting from a homicidal assault or murder does not qualify as an "accidental death" under the Mukhymantri Kisan Evam Sarvhit Bima Yojna.

A Division Bench comprising Justice Shekhar B. Saraf and Justice Abdhesh Kumar Chaudhary observed that while murder might be loosely termed an "accidental phenomenon" for the victim, it does not fall within the specific eligibility criteria strictly enumerated in the state's welfare scheme.

The petitioner, Nanhe Lal, moved the High Court challenging the rejection of his insurance claim following the death of his wife in October 2016. His wife was murdered by unknown assailants with a knife while she was cutting grass in a field, a fact supported by the post-mortem report. The authorities rejected the claim under the Mukhymantri Kisan Evam Sarvhit Bima Yojna on the ground that the nature of death did not meet the criteria for "accidental death" defined by the policy.

The primary question before the court was whether a death caused by a knife wound inflicted by unknown assailants constitutes an "accident" within the meaning of the Mukhymantri Kisan Evam Sarvhit Bima Yojna. The court was also called upon to determine if the principle of ejusdem generis applies to the interpretation of the specific events enumerated as "accidental" under the scheme.

Eligibility Strictly Defined By Enumerated Events

The court began by examining the specific language of the Mukhymantri Yojna, which provides insurance coverage for accidents resulting in disability or death. The Bench noted that the eligibility clause specifically lists events such as snake bites, lightning, drowning, and transport accidents. The court emphasized that the benefit can only be granted if the circumstances of the death fall squarely within these pre-defined categories.

"The events provided under the Eligibility Clause are specific and benefit can only be provided if the deceased falls within the said eligibility criteria," the court observed.

Murder Cannot Be Interpreted As An Accident Under The Scheme

Addressing the petitioner’s contention that a murder is an "accident" from the perspective of the victim, the Bench clarified that the scheme’s definitions are restrictive. While the scheme covers accidents involving railways, roadways, and air travel, it does not extend to criminal acts like murder. The court held that such a broad interpretation would go beyond the administrative intent of the policy.

"This accidental claim cannot be extended to cases where persons are murdered. Even though, loosely termed one may treat a murder as an accidental phenomenon, however such accidents are not covered under the said Mukhymantri Yojna," the Bench noted.

Application Of The Principle Of Ejusdem Generis

The court invoked the legal doctrine of ejusdem generis, which dictates that where general words follow specific words in a list, the general words must be interpreted to include only items of the same type as those specifically listed. The Bench reasoned that the "accidents" listed in the scheme share a common genus of uncertain physical mishaps, which murder—a deliberate homicidal act—does not share.

"The eligibility criteria has been specifically defined and the same can be interpreted for events which are ejusdem generis to the events enumerated therein," the court held.

Distinguishing Previous Precedents On Insurance Claims

The petitioner had relied on a 2019 Division Bench judgment in Smt. Bindu Devi vs. State of U.P., where a death by knife wound was allowed under the Samajwadi Kisan and Sarvhit Bima Yojana. However, the High Court distinguished the two cases, noting that the Mukhymantri Yojna is a "distinct scheme" with different terms from the one interpreted in the earlier ruling. Consequently, the previous precedent was found inapplicable to the present facts.

"The present Mukhymantri Yojna is different from the Scheme that was in operation and was interpreted by the Co-ordinate Bench in Smt. Bindu Devi. Thus, the said Co-ordinate Bench Judgment does not come to the aid of the petitioner," the Bench clarified.

Scope Of Beneficial Welfare Schemes

The court acknowledged that while the Yojna is a beneficial scheme intended to provide financial help to the needy, it cannot be stretched to cover deaths by any reason whatsoever. The object of the scheme is specifically tied to the unfortunate and uncertain events described within its framework. The court concluded that since the petitioner's wife's death did not occur due to an enumerated accident, no relief could be granted.

"The said Mukhymantri Yojna is not applicable due to death covered by any reason, except as provided in the scheme/Yojna itself," the court remarked.

The High Court dismissed the writ petition, holding that the claim for compensation was not maintainable under the specific terms of the Mukhymantri Kisan Evam Sarvhit Bima Yojna. However, the Bench granted the petitioner the liberty to avail himself of any other government welfare schemes that may have been applicable at the time of his wife's death.

Date of Decision: 15 April 2026