Cardiac Failure During Transit Constitutes Death Arising Out Of And In Course Of Employment For Compensation

The deceased, Ramey, was employed as a cleaner on a Borewell Truck (Reg. No. KA/01/AB/6185) owned by Respondent No. 4

On 07.10.2012, while traveling from Bangalore to Madhya Pradesh for work, he developed severe chest pain and was pronounced "brought dead" upon arrival at the hospital

The Post-Mortem Report (Ex-P/3) cited the cause of death as "coronary artery disease"

The Labor Court awarded Rs. 7,13,960/- as compensation plus 12% interest, and a penalty of Rs. 3,56,980/-

1. Whether the death of the employee due to coronary artery disease while on duty can be construed as an injury arising out of and in the course of employment

2. Whether the Labor Court’s assessment of the deceased's monthly income at Rs. 8,000/- was legally sustainable despite lower state-prescribed minimum wages

The Court applied Section 30 of the Employee’s Compensation Act, 1923, which governs appeals against the Commissioner's orders

doctrine of "notional extension" of employment and the principle that if the strain of work contributes to or accelerates a pre-existing condition (like heart disease) leading to death, it constitutes an "accident" arising out of employment

definition of "wages" which may include allowances beyond the base minimum wage prescribed under the Minimum Wages Act

The Court rejected the appellant's argument that coronary artery disease precluded the claim, reasoning that the immediate onset of chest pain while on a long-distance work transit indicated cardiac failure linked to the rigors of employment

The Court observed that the failure to use the specific phrase "heart failure" in the medical report did not negate the causal link to his duties

The Court held it was reasonable to conclude that additional daily allowances for food and travel brought the total monthly income to Rs. 8,000/-, making the Labor Court's assessment realistic rather than speculative

The award of compensation, interest, and penalty passed by the Labor Court was upheld