No Section 30 interference is warranted with the finding that employment-related stress caused death.

The claimants sought compensation under Section 22 of the Employees’ Compensation Act, 1923 (“EC Act”) following the death of Mukesh Kumar, an employee of the appellant Management.

They alleged that work-related stress and exertion caused a stroke on 6 September 2022, after the deceased attended a customer-related function the previous evening; he remained hospitalised until 29 September 2022 and died on 7 November 2022.

The Management admitted the employment and the deceased’s attendance at the function, but disputed that the death was attributable to his employment.

The Commissioner held the Management liable for compensation and funeral expenses, directing payment of principal compensation and interest.

The Management appealed under Section 30 of the EC Act.

1. Whether the deceased’s death arose out of and in the course of his employment, so as to entitle the claimants to compensation under the EC Act

2. Whether the Commissioner’s finding on the employment-related cause of death warranted interference in an appeal under Section 30 of the EC Act

Section 30 of the EC Act provides the basis for an appeal to the High Court and limits appellate interference with the Commissioner’s findings.

The Court relied on Syed Yakoob v. K.S. Radhakrishnan, AIR 1964 SC 477, and Golla Rajanna v. Divisional Manager, (2017) 1 SCC 45, in considering that limited scope of interference.

The Commissioner’s determination concerned whether the death was connected with the employment; the claimants’ case was treated as one of employment-induced stress and stroke, rather than a claim for a scheduled occupational disease.

The Court noted that the employment relationship was undisputed and that the Management admitted the deceased attended the customer-related function on 5 September 2022.

The deceased was hospitalised from 6 to 29 September, remained confined to bed thereafter, and died on 7 November 2022.

In light of these facts and the limited scope of appellate review under Section 30, the Court found no basis to interfere with the Commissioner’s conclusion that the deterioration in health was attributable to employment-related stress and stroke.

It directed that the amount deposited with the Registry or Commissioner be released to the claimants, together with any accrued interest, forthwith.

The delay in re-filing the appeal was separately condoned.