Heart attack during night shift duty constitutes an accident arising out of and in the course of employment.

The deceased, Mr. Mayavan, was a Senior Technician Grade I at Neyveli Lignite Corporation (NLC). On 01.12.2017, while working the night shift (third shift) at Mine-1A, he was found unconscious at approximately 6:00 AM the following morning

Although initial reports suggested a venomous bite due to external abrasions, the post-mortem report and viscera analysis concluded the cause of death was coronary artery heart disease (natural)

The widow (First Respondent) filed a claim under the Employees’ Compensation Act, 1923, asserting that the death resulted from work-related stress. The Labour Commissioner awarded Rs. 5,75,720/- with 12% interest, finding the heart attack was triggered by the rigors of the night shift within the mine

The appellant challenged this, arguing the death was natural and lacked a causal nexus with employment

1. Whether the death of the employee due to a heart attack is attributable to an accident arising out of and in the course of employment under Section 3 of the Employees’ Compensation Act, or if it was a natural death without nexus to the employer's service.

2. Whether the appellant is liable to pay compensation under Section 3(4) of the Act given the circumstances of the work environment.

The court primarily applied Section 3(1) of the Employees’ Compensation Act, 1923, which mandates employer liability for personal injury caused by an "accident arising out of and in the course of employment"

The court relied on the precedent set by the Supreme Court in Chairman, Vaidyanath Sahakari Sakhar Karkhana Ltd. Vs. Shantabhai (2025), which defined "accident" as an untoward, unexpected mishap, including heart attacks if a causal connection to work-related strain is established

It further considered Shakuntala Chandrakant Shreshti vs. Prabhakar Maruti Garvali (2007) regarding the three-pronged test: engagement in duties, occurrence at the workplace, and a non-remote causal link

and distinguished Jyothi Ademma Vs. Plant Engineer, Nellore (2006) which excludes compensation for purely natural deaths resulting from a pre-existing disease without work-related aggravation

The court reasoned that the term "accident" must be interpreted in its popular sense as an unintended mishap. In this case, the deceased was 53 years old and had no documented history of pre-existing heart disease

The court noted he was performing strenuous labor during a night shift in a mine environment

Applying the "stress and strain" test, the court found that working through the night in a mine provides a sufficient causal link between the employment conditions and the physiological collapse (heart attack)

The court verified that at the time of the "accident," the workman was at his duty station (Mine-1A) and actively engaged in his employment duties

Consequently, the heart attack was not a "natural result of disease" in isolation, but an event accelerated by the rigors of the job

The High Court dismissed the appeal and confirmed the order of the Labour Commissioner. The court permitted the widow to withdraw the entire deposited compensation amount of Rs. 5,75,720/- plus accrued interest. No costs were awarded