Causal link between employment and cardiac arrest must be established to claim compensation under the Act.

The deceased, Abdulbaksh Rangrej, was employed as a boiler attendant by the respondents.

On December 31, 1997, while on duty, he suffered a cardiac arrest and complained of chest pain after allegedly lifting heavy boxes and being exposed to hazardous chemicals

He was shifted to VS Hospital, where he died

The appellants (claimants) filed Workman Compensation Case No. 58 of 1998, which was dismissed by the Labour Court, Ahmedabad

The appellants approached the High Court under Section 30 of the Workman’s Compensation Act, 1923, contending that the death was a result of physical load and mental stress arising from the nature of the work

1. Whether the deceased met with an employment injury and whether the accident occurred during the course of and out of the employment

2. Whether there was a causal connection/nexus between the nature of the work (physical stress and chemical exposure) and the cardiac arrest leading to death

The court applied Section 3 of the Workman’s Compensation Act, 1923, which mandates that an injury must arise "out of and in the course of employment" to qualify for compensation

It relied on the precedent Mackinnon Mackenzie And Company Private Limited v. Ibrahim Mahmmed Issak (1969), which established that the burden of proof rests on the claimant to prove the accident arose out of employment, though this may be inferred from proved facts

Furthermore, it applied Shakuntala Chandrakant Shreshti v. Prabhakar Maruti Garvali & Anr. (2007), which held that there must be a causal connection between the injury and the work, and that heart disease is not automatically considered an occupational injury without evidence of employment-contributed strain

The Court observed that the burden of proving a causal link between the death and the employment rested solely on the claimants

Upon reviewing the evidence, the Court found that the witnesses (claimants and a co-worker) failed to testify that the deceased suffered from prior physical or mental stress or trauma related to his job

The Court noted the total absence of medical evidence, specifically the Post Mortem (PM) report, which is vital to establishing the cause of death in heart-related cases

It reasoned that while heart disease can be triggered by stress, it is not an "occupational disease" by default; without evidence of a specific mishap or evidence that the employment "contributed" to the death, the claim cannot succeed

The court concluded that the findings of the Workman Commissioner were fair and practicable as no "employment injury" was proved

The Court confirmed the Labour Court's order but clarified that any dependency benefits already paid to the claimants should not be recovered

The Registry was directed to return the Record and Proceedings to the lower court