Claimant must prove causal nexus between employment stress and heart attack to receive employee compensation.

The appellants represent the family of Harishbhai Dayabhai Patel, a waiter/peon at a restaurant run by Gujarat Tourism, Saputara

On September 26, 2002, the deceased allegedly reported to duty at 6:00 AM, developed sudden chest pain, was taken to the hospital by a co-worker, and subsequently died

The Workman Compensation Commissioner, Navsari, dismissed the claim in 2007 on the grounds that the deceased’s presence was not recorded in the muster roll for that day and no causal link between employment and death was established

1. Whether the deceased was "on duty" at the time of the incident despite the absence of a "present" entry in the muster roll

2. Whether the death due to a heart attack can be classified as an injury "arising out of and in the course of employment" under the Employees' Compensation Act

Section 3 of the Employees' Compensation Act, 1923, which requires that an injury or death must arise "out of" and "during the course of" employment

Mackinnon Mackenzie And Company Pvt. Ltd. v. Ibrahim Mahmmed Issak (1969), establishing that the claimant bears the burden of proving a causal relationship between the accident and employment

Shakuntala Chandrakant Shreshti v. Prabhakar Maruti Garvali Anr. (2007), which held that heart failure must have a "crucial link" with work-related stress or trauma to be compensable

Saidabanu Abdulkarim Rangrej v. Manager Everchem Dyes Industries (2026) regarding the necessity of medical evidence (like a post-mortem) to link death to occupational stress

The Court observed that while the muster roll showed no entry for "presence," it also showed no entry for "absence," creating an ambiguous record

The Court placed heavy weight on the widow's cross-examination, where she admitted to having no documentary evidence of her husband's presence on the day of the incident and could not affirm if his service caused him stress

Applying the Mackinnon Mackenzie test, the Court found that the claimants failed to discharge the burden of proof

The Court reasoned that heart disease is not automatically an occupational disease; there must be evidence that the work-related strain contributed to or aggravated the condition

Since no post-mortem report was produced and no evidence of work-related trauma was led, the Court concluded there was no "causal connection" between the waiter's duties and the cardiac arrest

The Court upheld the Commissioner's decision, finding no jurisdictional error. The First Appeal was dismissed, and any interim relief was vacated