Mill Worker Who Fainted While Loading Cotton: Madras HC Upholds Insurer’s ₹3 Lakh Liability For Her Work-Related Death

Kumuthavalli, employed as a cotton-loading helper at the second respondent’s textile mill, fainted while working on 16 November 2016 and was declared dead on arrival at hospital.

Her son claimed compensation, alleging that heavy work and stress caused her death; the employer disputed the alleged wage and contended that the death did not occur in the course of employment.

The mill had a group personal accident policy covering 1,800 workmen, with a maximum benefit of Rs. 3,00,000 per workman.

The Commissioner found that the death arose out of and in the course of employment, assessed compensation at Rs. 5,32,800, and directed the insurer to pay Rs. 3,00,000 and the employer to pay the balance, with 12% annual interest from the accident date.

The insurer alone appealed.

Section 3(1) of the Employees’ Compensation Act, 1923 imposes liability where personal injury is caused by an accident arising out of and in the course of employment; an employment-related mishap may qualify even without external injury where the nature of the work materially contributes to the death.

The Court relied on Param Pal Singh v. National Insurance Company Ltd., 2013 (1) TNMAC 1 (SC), which held that an unexpected death from heart failure, materially contributed to by the strain of long-distance driving, could constitute an accident arising out of and in the course of employment.

Section 4A(3) of the Act provides for simple interest at a minimum rate of 12% per annum, or such higher prescribed rate as may apply.

The Court treated the circumstances of Kumuthavalli’s death as comparable to those in Param Pal Singh: she fainted while performing strenuous work, and the Court found that work pressure or heavy work contributed to her death.

It therefore rejected the insurer’s contention that the absence of external injury meant no accident had occurred, and upheld the finding that the death arose out of and in the course of employment.

The policy was in force on the accident date and limited the insurer’s liability to Rs. 3,00,000; the Court noted that the quantum was not disputed.

On interest, it held that Section 4A(3) prescribed 12% annual interest and that the Commissioner had no power to reduce it.

The judgment does not separately explain how the insurer’s impleadment date affected the interest issue.

It confirmed the Commissioner’s award, including the insurer’s liability for Rs. 3,00,000 with 12% annual interest from the accident date; there was no order as to costs, and the connected miscellaneous petition was closed.