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 | Binding |
| Overrules / Affirms |
|
| Type of Law | Workmen’s Compensation Act, 1923 |
| Questions of Law | Whether the High Court erred in setting aside the Commissioner’s finding of an employer-employee relationship and the compensation award absent perversity |
| Ratio Decidendi |
The Supreme Court held that a fact-finding body’s conclusion grounded on both documentary evidence and oral admissions is not open to appellate interference except where the finding is perverse. The Commissioner’s conclusion that the deceased was employed as a driver prior to and at the time of the accident was supported by the vehicle owner’s testimony and later affidavit admissions. The High Court’s reliance on the owner’s initial denial was held to be an erroneous basis for upsetting the award. Appellate courts must respect factual findings unless they suffer from a legal infirmity or perversity. |
| Logic / Jurisprudence |
|
| Facts as Summarised by the Court |
|
Practical Impact
| Category | Impact |
|---|---|
| Overrules | High Court’s order dated 22.03.2022 in CMA No. 98/2010 |
What’s New / What Lawyers Should Note
- Appellate interference under Section 482 CrPC or similar provisions is confined to cases where the fact-finder’s conclusion is perverse.
- Oral admissions—even post-warrant—can conclusively establish an employment relationship.
- Denials in early pleadings to evade civil liability cannot sustain an appeal against a compensation award.
- Restoration of a compensation award underscores the primacy of the Commissioner’s fact-based findings.
Summary of Legal Reasoning
- The High Court’s acceptance of the vehicle owner’s initial counter-affidavit denial was held to be erroneous in light of subsequent admissions.
- The Commissioner’s finding of employment was based on documentary proof and the owner’s evidence confirming that the deceased was in his service when the accident occurred.
- The principle that appellate courts may not upset fact-based findings absent perversity was applied to reject the High Court’s interference.
- Non-appearance and issuance of warrants led to an unequivocal affidavit admission by the owner, solidifying the employer-employee relationship.
- In consequence, the original compensation award was restored.
Factual Background
On 10 September 2004, a driver employed on a monthly salary of ₹3,500 (plus daily batta) was killed in a vehicular collision during the course of his employment. The legal representative filed a claim under the Workmen’s Compensation Act, 1923. The Commissioner found that an employer-employee relationship existed and awarded ₹3,73,747 with 12% interest. The High Court set aside this award based on an initial denial by the vehicle owner. The Supreme Court restored the award after the owner admitted employment in a subsequent affidavit.
Alert Indicators
- ✔ Precedent Followed