In a significant ruling on employee insurance claims, the Gujarat High Court has set aside compensation granted to the family of a deceased worker, holding that a heart attack alone cannot be treated as an “employment injury” without clear evidence linking it to job conditions.
Background of the Case
The case arose from the death of Ramanbhai Shivabhai Patel, a fitter mechanic employed at Bajaj Processors. On September 6, 2004, while on duty during the second shift, he complained of chest and abdominal pain and was later declared dead at a hospital.
A postmortem attributed the cause of death to “cardio-respiratory arrest due to coronary heart disease.”
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His family initially sought benefits from the Employees’ State Insurance Corporation (ESIC), but the claim was rejected. The ESI Court later allowed the claim, granting dependency benefits. Challenging this, ESIC approached the High Court.
Appearing for ESIC, counsel argued that a heart attack, by itself, does not qualify as an employment injury unless supported by evidence showing work-related stress or strain caused the condition. It was submitted that no such evidence was placed on record.
On the other hand, the claimant’s counsel contended that the deceased was under physical workload and stress, which contributed to his condition. It was also argued that under the ESI Act, a presumption exists in favour of the employee when an incident occurs during employment.
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Justice J.C. Doshi examined the scope of “employment injury” under the Employees’ State Insurance Act and reiterated that there must be a clear causal connection between employment and the injury.
The Court noted that although the worker died during duty hours, no concrete evidence established that his heart condition was caused or aggravated by his work.
“The claimant did not lead any evidence to link the nexus of death with the employment injury,” the Court observed.
It further clarified that mere occurrence of death at the workplace is not sufficient. There must be proof that the employment contributed to or caused the injury.
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Rejecting the argument of presumed stress, the Court remarked that such a conclusion “cannot be a matter of surmise or conjecture” and must be backed by evidence.
Allowing the appeal, the High Court set aside the ESI Court’s order granting dependency benefits. The Court held that in the absence of evidence proving that the death arose out of and in the course of employment, no compensation could be awarded under the ESI Act.
However, the Court clarified that any benefits already paid to the claimant would not be recovered.
Case Details
Case Title: Employees State Insurance Corporation vs Sudhaben Ramanbhai Patel & Ors.
Case Number: First Appeal No. 656 of 2011
Judge: Justice J. C. Doshi
Decision Date: April 2, 2026
