Employment-related cardiac death may qualify as an accident where work strain contributes to or accelerates the collapse.

Death from sudden cardiac failure while on duty may be treated as an accident arising out of and in the course of employment where the work creates or aggravates the strain leading to death. Applying Section 3 of the Employees Compensation Act, 1923, the Court reiterated that compensation depends on a causal connection between employment and injury or death, including where work-related stress contributes to or accelerates an internal collapse. On that test, the Court held that the Commissioner had not applied the correct legal standard for employment-related accidental death, and the compensation claim was restored for fresh adjudication.

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Issues: Whether the death of a tanker driver from sudden cardiac failure while on duty could be treated as an accident arising out of and in the course of employment for the purpose of compensation under Section 3 of the Employees Compensation Act, 1923.

Analysis: The Court applied Section 3 of the Employees Compensation Act, 1923 and the settled principle that compensation is payable where there is a causal connection between the employment and the injury or death. Relying on the nature of long-distance driving and the admitted stressful work conditions, the Court held that heart failure or sudden collapse may amount to an accident if the work-related strain contributed to or accelerated the death. The Court found that the Commissioner had not correctly appreciated the legal test for employment-related accidental death.

Conclusion: The issue was answered in favour of the claimants-appellants, and against the respondents, because the death was capable of being treated as employment-related and accidental within the meaning of Section 3.

Final Conclusion: The appeal succeeded, the rejection of the compensation claim was set aside, and the matter was remitted for fresh adjudication in accordance with law.

Ratio Decidendi: Death caused by heart failure or similar internal collapse can constitute an accident under the Employees Compensation Act, 1923 if the employment and its attendant stress or strain are shown to have a causal connection with the death, or to have contributed to or accelerated it.

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