Supreme Court Sets Aside High Court Decision, Awards Compensation to Claimants in Landmark Workmen's Compensation Case

In a significant ruling, the Supreme Court of India overturned a judgment by the High Court of Judicature at Patna and awarded compensation to the claimants in a civil appeal pertaining to the Workmen's Compensation Act. Justice Aravind Kumar, delivering the judgment along with Justice J.K. Maheshwari, stated, "The claim petition was maintainable before the Deputy Labour Commissioner-cum-Commissioner for Workmen Compensation."

The case involved the appellants, Mamta Devi & Ors., who sought compensation for the death of Sri Vakil Choudhary, employed as a truck driver, in a road accident. The High Court had previously held the claim to be outside its jurisdiction, deeming it a contested matter. However, the Supreme Court found that the claim did not meet the criteria of a contested claim, as the insurer had filed a written statement but failed to pursue further contestation, and the employer had admitted the claimant's averments.

Justice Kumar emphasized, "The unchallenged statement of the wife of the deceased, who deposed that her husband was earning Rs.6,000/- per month, deserves to be accepted as gospel truth." Based on this, the Court recalculated the compensation and determined it to be Rs.6,64,110/- (Rupees Six Lakhs Sixty Four Thousand One Hundred and Ten only), along with interest at 12% per annum.

The Supreme Court's decision brings relief to the claimants, who had been awaiting reasonable compensation. Justice Kumar further noted, "In the normal course, we would have remitted the matter back to the High Court for adjudicating the appeal on merits. However, we desist from doing so..."

This landmark judgment serves as a reminder of the importance of social justice in workmen's compensation cases. The Court's ruling upholds the jurisdiction of the Deputy Labour Commissioner-cum-Commissioner for Workmen Compensation and sets a precedent for similar cases in the future.

The judgment also highlights the need for accurate computation of income and the obligation of employers to provide truthful information. It reinforces the principle that compensation should be fair and commensurate with the wages earned by individuals in their respective occupations.

The case is expected to have a significant impact on the interpretation and application of the Workmen's Compensation Act, 1923, and may guide future litigation in this area.

Date of Decision: May 19, 2023

Mamta vs THE RELIANCE GENERAL INSURANCE COMPANY LIMITED & ANR.