Madras High Court grants ₹15 lakh COVID compensation to deceased FCI worker’s daughters despite death certificate citing cardiac arrest

The petitioners were the daughters and legal heirs of G. Johnson, a labourer employed by the Food Corporation of India (“FCI”). Johnson tested positive for COVID-19 on 31 May 2021 and was admitted to FCI’s accredited hospital. He was discharged on 10 June 2021 with instructions to remain in quarantine for a further 14 days. He resumed duty on 12 July 2021 and died on 15 July 2021. Although the death report submitted by the petitioners referred to COVID-19, the municipal medical certificate recorded the immediate cause of death as “cardiac arrest”.

FCI had issued Circular No. 24-2020-16 dated 11 April 2020, under which the family of a labourer who died due to COVID-19 was entitled to monetary compensation of ₹15,00,000. The petitioners sought payment under the scheme through a representation dated 24 November 2021. FCI rejected the claim on the ground that the death certificate did not state that the death was due to COVID-19 and that the deceased had been discharged from treatment and had resumed duty before his death. The petitioners accordingly invoked Article 226 of the Constitution seeking a writ of mandamus for payment of the compensation.

1. Whether the recording of “cardiac arrest” as the immediate cause of death was sufficient to deny the petitioners’ claim for COVID-19 compensation under FCI’s beneficial scheme.

2. Whether, in light of the deceased’s COVID-19 infection, continuing quarantine and treatment, and death within 45 days of testing positive, his death could reasonably be treated as a COVID-19 death despite occurring beyond the scheme’s stated 30-day period.

3. Whether the petitioners were entitled to a writ of mandamus directing FCI to sanction and disburse ₹15,00,000 under the circular.

The Court applied Article 226 of the Constitution, observing that a writ of mandamus could issue to enforce the petitioners’ entitlement under FCI’s COVID-19 compensation Circular No. 24-2020-16 dated 11 April 2020, which provided ₹15,00,000 to the family of a labourer dying due to COVID-19.

It relied on the Government of India’s Office Memorandum dated 3 September 2021 and the COVID-19 death-documentation guidelines issued pursuant to the Supreme Court’s orders, including the medical data that approximately 95% of COVID-19 deaths occurred within 25 days of a positive test and the guideline treating specified deaths within the relevant period as COVID-19 deaths.

The Court further applied the principle of beneficial interpretation: remedial and social-security schemes must receive a liberal and purposive construction, and where two interpretations are possible, the interpretation favouring the beneficiary should be adopted. It relied on Maniben Maganbhai Bhariya v. District Development Officer, (2022) 16 SCC 343, and Urmila Dixit v. Sunil Sharan Dixit, (2025) 2 SCC 787.

The Court found a substantial and reasonable nexus between Johnson’s confirmed COVID-19 infection and his subsequent death. He had tested positive on 31 May 2021, had required hospitalisation, remained subject to quarantine after discharge, and died on 15 July 2021 while the medical records indicated continuing treatment and no clear basis to exclude COVID-19 complications.

The Court held that “cardiac arrest” described only the immediate mechanism of death and could not, in the circumstances, conclusively displace the evidence connecting the death with COVID-19. It also noted that the applicable documentation guidelines were issued after the death and that the family had promptly reported the death as COVID-related.

Although the death occurred 15 days beyond the 30-day period referred to in the scheme and the deceased had not returned to the accredited hospital for review, the Court considered the contemporaneous treatment records, the continuing infection, and the exceptional conditions during the second wave of the pandemic.

Applying the beneficial-interpretation principle, the Court resolved the evidentiary doubt in favour of the deceased employee’s legal heirs.

The writ petition was allowed, and the respondents were directed to sanction and disburse ₹15,00,000 to the petitioners within four weeks from receipt of the order. Any delay in payment would attract interest at 6% per annum from the date of receipt of the order until actual disbursement. No costs were imposed.