Death arising from brain hemorrhage during the course of employment constitutes a compensable accidental injury.

The deceased, Sudesh Kumar Kaushik, was employed as a laborer by Respondent No. 2, Mahamaya Rice Industries

On August 26, 2017, while performing his duty of checking rice storage, he suffered a brain hemorrhage, fell, and was subsequently declared brought dead at the hospital

The Post Mortem report confirmed the cause of death as brain hemorrhage resulting from increased pressure in the blood vessels

The grandmother of the deceased (Respondent No. 1) filed a claim under the Employees Compensation Act, 1923.

The Commissioner, Labour Court, Bilaspur, awarded compensation of Rs. 8,30,138/- with 12% interest

The Insurance Company appealed, contending they were not liable as the death was due to a medical condition (hemorrhage) rather than an accident

Whether the deceased died due to a brain hemorrhage during the course of employment, and whether fastening liability upon the Insurance Company for such a death is illegal?

Section 3 of the Employees Compensation Act, 1923 (formerly Workmen's Compensation Act), which mandates employer liability for compensation if personal injury is caused to an employee by an "accident arising out of and in the course of employment."

The legal principle establishes that if the employment is a contributory cause or the environment of the job accelerated the incident, it qualifies as an accident, regardless of whether the internal cause was a pre-existing medical condition like a hemorrhage

The Court observed that the fact the deceased was actively performing his duties (checking storage) at the time of the collapse was undisputed

Although the Insurance Company suggested the fall might have been due to an epileptic seizure, the Post Mortem report specifically attributed the death to a brain hemorrhage

The Court reasoned that for the purpose of granting compensation under the EC Act, the primary determination is whether the death occurred "during the course of employment"

It held that the specific medical "cause of death" (brain hemorrhage) does not negate the employer's liability if the link between the employment and the incident is established

Since the deceased was on duty when the hemorrhage occurred, it is legally treated as an accident arising out of employment

The Court affirmed that death due to brain hemorrhage while on duty constitutes an accident under the Employees Compensation Act. The appeal was dismissed, and the Labour Court’s award of Rs. 8,30,138/- with 12% interest was upheld