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Issues: Whether the death by cardiac arrest while the workman was on duty constituted an accidental injury arising out of and in the course of employment so as to attract compensation under the Workmen's Compensation Act, 1923.
Analysis: Compensation under the Act depends on proof that the workman suffered an injury caused by an accident and that the accident arose out of and in the course of employment. A mere death during employment is not enough. The claimant must establish, by pleadings and evidence, a causal connection between the employment, the stress or strain of the work, and the death. Cardiac arrest by itself does not create a presumption of accident. In the absence of evidence showing that the work duties were strenuous or that the employment contributed to the heart failure, the necessary jurisdictional facts are not proved.
Conclusion: The death was not proved to be the result of an accidental injury arising out of and in the course of employment, and compensation was not payable.