Farm-Dependent Wife Who Worked Husband’s Land Can Qualify For UP Farmer Accident Scheme Despite No Land In Her Name; Allahabad HC Orders Fresh Decision

In brief

The question

1. Whether a deceased woman who worked on agricultural land recorded in her husband’s name could qualify under Clause 2(2) of the Scheme as an earning family member, despite not being a recorded tenure-holder or bataidar.

The court held

The Court held that Meera was an earning family member whose principal source of livelihood was agricultural income derived from the holding recorded in the petitioner’s name, and that she fell within Clause 2(2) of the Scheme.

It also directed

It allowed the petition and quashed the District Magistrate’s rejection order dated 24 May 2022.

The District Magistrate was directed to pass a fresh order in accordance with the judgment within four weeks of production of a certified copy.

01Facts

The petitioner’s wife, Smt. Meera, died in a road accident on 20 August 2020.

¶ 3–4

He applied for benefits under the Mukhyamantri Krishak Durghatna Kalyan Yojana, relying on, among other documents, a Khatauni recording him as a co-tenure-holder and a family-register extract identifying agriculture as the household’s occupation.

¶ 3–4, 21–22

The District Magistrate rejected the claim because Meera had no land recorded in her name and was not a bataidar.

¶ 5

The petitioner challenged that rejection, contending that Meera worked in agriculture and that agriculture was her principal source of livelihood.

¶ 6–7

02Issues

i.1. Whether a deceased woman who worked on agricultural land recorded in her husband’s name could qualify under Clause 2(2) of the Scheme as an earning family member, despite not being a recorded tenure-holder or bataidar.

¶ 10, 15

ii.2. Whether the material on record established that Meera’s principal source of livelihood was agricultural income derived from the petitioner’s recorded holding.

¶ 22–26

03Law Applied

Clause 2 of the Scheme provides alternative eligibility categories: recorded tenure-holders or co-tenure-holders under Clause 2(1); earning family members of a tenure-holder or co-tenure-holder whose principal livelihood is agricultural income from the recorded land under Clause 2(2); and certain landless agricultural workers under Clause 2(3).

¶ 11–12

A claimant under Clause 2(2) need not independently satisfy Clause 2(1) or Clause 2(3), and the deceased need not have land recorded in her own name.

¶ 12, 15

Clause 11(j) prescribes documentation for claims involving persons under Clauses 2(2) and 2(3).

¶ 13–14

The Scheme is a beneficial welfare measure and must be interpreted to advance its purpose while retaining its prescribed conditions.

¶ 16

The Court relied on Smt. Gayatri Devi v. State of U.P. and Others, Writ-C No. 29414 of 2021 (decided 18 December 2025), and Rajesh Kumar v. State of U.P. and Others, Writ-C No. 1006 of 2026 (decided 24 March 2026), concerning actual agricultural work and livelihood under the Scheme.

¶ 17–18

It also referred to the beneficial-interpretation principle in Union of India v. Prabhakaran Vijaya Kumar, (2008) 9 SCC 527.

¶ 17

Provisions in the judgment · 2 · Linked ones open on LawLens

Indian Penal Code, 1860 Section 279

Motor Vehicles Act, 1988 Section 184

04Reasoning

The Court held that the District Magistrate had wrongly treated ownership in the deceased’s own name and bataidar status as necessary conditions, thereby overlooking the separate eligibility category in Clause 2(2).

¶ 12, 15, 25

The petitioner was admittedly a recorded co-tenure-holder, and the family-register extract recorded agriculture as the household’s occupation; the State produced no material showing that Meera’s principal livelihood came from another source.

¶ 21–22

The petitioner’s tea-shop earnings did not establish that Meera herself derived her principal livelihood from the shop, and her participation in cultivation was not negated by her husband’s separate income.

¶ 23

The Court further held that Clause 2(2) does not require a person to be the family’s sole breadwinner or to receive separate wages for work on the family holding.

¶ 19–20