Panganti Vijaya Vs United India Insurance Company Ltd. & Ors. (Supreme Court of India)
Employer’s Subsequent Admission Restores Compensation: High Court Cannot Reappreciate Facts in Workmen’s Compensation Appeals
The Supreme Court set aside the High Court’s judgment which had reversed the award of compensation under the Workmen’s Compensation Act, 1923, holding that the High Court erroneously interfered with well-reasoned findings of fact recorded by the Commissioner. The Court reaffirmed that in appeals under the Act, the High Court’s jurisdiction is limited to substantial questions of law, and it cannot reappreciate evidence or substitute its own factual conclusions unless the findings are perverse or unsupported by record.
On facts, the deceased was employed as a driver and died in a road accident occurring during the course of employment. Although the vehicle owner initially denied the employer–employee relationship in his counter-affidavit, he admitted the employment during cross-examination and again unequivocally affirmed it on oath before the Supreme Court, explaining that the earlier denial was made to avoid civil liability. The Commissioner had correctly relied on this evidence, along with other material on record, to hold that the accident arose out of and in the course of employment.
The Supreme Court found that the High Court misread the record, relied on an earlier denial while ignoring subsequent admissions, and even committed factual errors regarding the lodging of the FIR. Such interference, in the absence of perversity, was held to be legally impermissible.
Accordingly, the appeal was allowed, the High Court judgment was set aside, and the original award of compensation with 12% interest passed by the Commissioner was restored. The appellant was also permitted to withdraw the balance amount lying in deposit, reinforcing the principle that beneficial labour legislation must be interpreted in favour of employees and their dependants
FULL TEXT OF THE SUPREME COURT JUDGMENT/ORDER
