Summary
| Category | Data |
|---|---|
| Court | Supreme Court of India |
| Case Number | C.A. No.-000049-000049 – 2026 |
| Diary Number | 47155/2023 |
| Judge Name | HON’BLE MR. JUSTICE VIKRAM NATH |
| Bench |
HON’BLE MR. JUSTICE VIKRAM NATH HON’BLE MR. JUSTICE SANDEEP MEHTA |
| Precedent Value | Affirms appellate restraint in interference with factual findings in compensation awards |
| Overrules / Affirms | Affirms the Commissioner’s award; overrules the High Court’s interference |
| Type of Law | Workmen’s Compensation Act, 1923 (Labour Law) |
| Questions of Law |
|
| Ratio Decidendi |
The Supreme Court held that a High Court must desist from upsetting a compensation commissioner’s findings unless they are perverse. The Commissioner had correctly appreciated both documentary evidence and the owner’s admission that the deceased was employed as a driver when the fatal accident occurred in the course of employment. Relying on an earlier contradictory counter-affidavit and misrecorded FIR details was legally unsound. Subsequent sworn admission by the vehicle owner before this Court further corroborated the employment relationship. Accordingly, the Commissioner’s award was restored and the High Court’s order set aside. |
| Judgments Relied Upon | None specifically cited |
| Logic / Jurisprudence / Authorities Relied Upon by the Court |
|
| Facts as Summarised by the Court |
|
Practical Impact
| Category | Impact |
|---|---|
| Binding On | All subordinate courts |
| Persuasive For | High Courts in compensation appeals (as confirmation of restraint) |
| Overrules | High Court of Telangana in CMA No. 98/2010 |
What’s New / What Lawyers Should Note
- Clarifies that High Courts cannot disturb a commissioner’s factual findings in compensation matters absent perversity.
- Establishes that admissions in cross-examination and sworn affidavits conclusively prove employer-employee relationships.
- Holds that reliance on initial contradictory pleadings or misrecorded FIR details is legally infirm.
- Demonstrates the use of appellate warrants to secure party admissions when contested.
Summary of Legal Reasoning
- The High Court erred by relying on an earlier counter-affidavit and misrecorded FIR details to deny the employment relationship.
- The Commissioner’s finding was based on consistent oral and documentary evidence, including the owner’s admission.
- No perversity existed in the Commissioner’s fact-finding; appellate courts must respect such findings.
- Respondent No. 5’s sworn affidavit before this Court unequivocally admitted the employment and salary terms.
- The Supreme Court restored the Commissioner’s award and set aside the High Court’s order.
Arguments by the Parties
Appellant (Legal Representative of Deceased):
- The deceased was employed as a driver at ₹3,500 per month (+₹50 per day).
- The fatal accident occurred in the course of employment.
- The Commissioner correctly awarded compensation; High Court wrongly interfered.
Respondent No. 1 (United India Insurance Company):
- Challenged the existence of an employer-employee relationship and liability.
Respondent No. 5 (Vehicle Owner):
- Initially denied employment in counter-affidavit to avoid liability.
- Later, in cross-examination and affidavit filed before this Court, admitted the employment and salary details.
Factual Background
Pursuant to employment at ₹3,500 per month (+₹50 per day batta), the deceased driver met with a fatal road accident on 10.09.2004 while driving the employer’s vehicle. The legal representative filed a claim under the Workmen’s Compensation Act, 1923. The Commissioner awarded ₹3,73,747 with 12% interest on finding an employer-employee relationship and course of employment. The High Court set aside that award; the Supreme Court restored it after reviewing evidence and securing a sworn admission from the vehicle owner.
Statutory Analysis
Under the Workmen’s Compensation Act, 1923, compensation is payable for death arising out of and in the course of employment. The Court found both elements satisfied—employment status established by admission, and accident occurring during authorized duties.
Alert Indicators
- ✔ Precedent Followed – Affirms non-interference standard in appellate review of commissioners’ factual findings.