Gauhati High Court

Statutory compensation for electrical accidents applies only if the incident is attributable to licensee negligence.

Kalpana Mahanta vs The State Of Assam And 4 Ors

Gauhati High CourtJUDGMENT: June 25, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The petitioner, a tenant in the house of respondent No. 5, filed a writ petition regarding the death of her minor daughter, Himashree Das

Source reference: p. 3

On 19.05.2024, the daughter came into contact with a live high-voltage wire while on the building's terrace, resulting in fatal burn injuries; she succumbed to these injuries on 23.05.2024 at GMC&H

Source reference: p. 3

An FIR was filed on 06.05.2024 (sic)

Source reference: p. 3

The petitioner submitted a representation for compensation to the Managing Director of the Assam Power Distribution Company Limited (APDCL) on 14.08.2025, which remained unconsidered

Source reference: p. 3, 5
02

Issues

1. Whether the APDCL is liable to pay compensation for the death caused by an electrical accident under the AERC Regulations

Source reference: p. 3-4

2. Whether the non-consideration of the petitioner’s representation constitutes a failure of statutory duty by the licensee

Source reference: p. 3, 5
03

Law Applied

Assam Electricity Regulatory Commission (Compensation to Victims of Electrical Accidents) Regulations, 2019, notified under Sections 181(1), 57(2), and 57(3) of the Electricity Act, 2003

Source reference: p. 3

Specifically, Section 5 establishes liability if the accident is attributable to the licensee’s negligence; Section 6 and Schedule B fix the quantum for loss of human life at ₹4,00,000/-; Section 15 outlines the application procedure via Form B; and Section 20 mandates payment within 120 days of the accident, failing which a 12% per annum interest is applicable

Source reference: p. 4-5
04

Reasoning

The Court noted that while the petitioner did not strictly follow the procedural requirement of filing "Form B" under Annexure-II, a formal representation was indeed received by the MD of APDCL on 14.08.2025

Source reference: p. 5

The Court reasoned that the statutory framework under the 2019 Regulations creates a time-bound duty for the licensee to investigate and determine compensation once an accident is reported

Source reference: p. 4

Because it could not determine negligence in the absence of the Chief Electrical Inspector’s report or APDCL’s response, the Court emphasized that the MD of APDCL must treat the pending representation as a formal application

Source reference: p. 6

The Court highlighted that if negligence is found, the licensee is legally bound by Section 20 to pay interest due to the delay exceeding the 120-day statutory limit

Source reference: p. 5-6
05

Holding

The Court disposed of the writ petition by directing the Managing Director, APDCL, to consider the petitioner’s representation as a "Form B" application

The MD must obtain a report from the Chief Electrical Inspector to determine if the accident was attributable to the licensee's fault. If attributable, compensation of ₹4,00,000/- plus 12% interest must be paid. If rejected, a speaking order must be issued. This process is to be completed within six months of the petitioner providing the certified order, FIR, post-mortem report, and death certificate

Source reference: p. 6-7
Gauhati High Court

Original Court PDF

Kalpana MahantavsThe State Of Assam And 4 Ors

Gauhati High Court · June 25, 2026

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