The Supreme Court recently ruled in favor of two employers accused of failing to provide adequate safety equipment to their workers, leading to a fatal workplace accident. The case involved two employees who were electrocuted while working on a shop’s signboard using an iron ladder.

The employers were initially charged under Section 304 (culpable homicide not amounting to murder) and Section 304A (causing death by negligence) of the Indian Penal Code (IPC). Both the Trial Court and High Court rejected their discharge applications, holding that there was enough evidence to proceed under Section 304 Part II IPC.

The Employers’ Defense and Supreme Court’s Decision

The accused employers challenged these rulings in the Supreme Court, arguing that they did not have the intention or knowledge required to be held liable under Section 304 Part II IPC. Their defense stated that while the incident was unfortunate, it was purely accidental and did not result from any deliberate act of negligence.

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The Supreme Court, comprising Justice Abhay S. Oka and Justice Ujjal Bhuyan, agreed with the appellants and observed:

“The two deceased employees were decorating the front of the shop using an iron ladder. Unfortunately, they suffered an electric shock, fell from a height of 12 feet, and sustained fatal injuries. This was purely accidental. There is no prima facie case under Section 304A IPC, let alone Section 304 Part II IPC.”

The Court emphasized that at the discharge stage, the lower courts should have taken a prima facie view to determine whether the charges against the accused had sufficient merit.

The Supreme Court ruled that the essential elements of Section 304 Part II IPC—intent and knowledge—were missing in this case. There was no evidence to suggest that the employers:

• Had any intention to cause death.
• Possessed knowledge that their actions were likely to result in death.
• Engaged in any reckless or negligent behavior that directly led to the accident.

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The Court also noted that while providing safety gear is an important employer responsibility, failure to provide certain safety equipment alone does not necessarily constitute a criminal offense.

The prosecution cited the Keshub Mahindra v. State of M.P. case, related to the Bhopal Gas Tragedy, to argue for employer liability. However, the Supreme Court clarified that the circumstances in this case were vastly different. Unlike the Bhopal case, which involved gross negligence leading to thousands of deaths, this incident was an unforeseen workplace accident with no deliberate disregard for safety.

With these observations, the Supreme Court set aside the High Court and Trial Court rulings and allowed the appeal, effectively discharging the two employers from criminal liability.

“In the absence of evidence proving intent or knowledge, there are no grounds to proceed with criminal charges under Section 304 Part II IPC. The appellants are hereby discharged.”

Case Title: YUVRAJ LAXMILAL KANTHER & ANR. VERSUS STATE OF MAHARASHTRA