High Court Dismisses Insurance Company Appeal in Workmen's Compensation Case - Employer-Employee Relationship Established Through Unrebutted Testimony - Compensation Award of Rs.3,49,290 with 6% Interest Upheld

Sub Category: Karnataka High Court Bench: BENGALURU
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Case Note & Summary

The High Court dismissed an insurance company's appeal challenging a workmen's compensation award, holding that the claimant's unrebutted evidence established an employer-employee relationship. The claimant, injured while driving the insured vehicle, testified about his employment as driver with monthly wages of Rs.10,000. The vehicle owner denied the relationship in written statement but failed to appear for evidence. The Court found no error in the Tribunal's conclusion that employment relationship existed, as the owner's denial remained unsubstantiated by evidence. The compensation of Rs.3,49,290 with 6% interest was upheld.

Headnote

The High Court of Karnataka at Bengaluru dismissed an appeal filed by SBI General Insurance Company Ltd. challenging a compensation award under the Workmen's Compensation Act, 1923 -- The appellant Insurance Company contended that no employer-employee relationship existed between the claimant and vehicle owner -- The Court examined the evidence where the claimant testified about his employment as driver with monthly wages of Rs.10,000 -- The vehicle owner filed written statement denying employment relationship but failed to appear for evidence or produce any contrary evidence -- The Trial Court had awarded Rs.3,49,290 with 6% interest from accident date -- The High Court held that the unrebutted testimony of the claimant established the employment relationship -- The appeal was dismissed confirming the compensation award -- The judgment emphasizes that when employer fails to lead evidence against employment claim, the claimant's evidence remains unchallenged and establishes the relationship

Issue of Consideration: Whether the learned Trial Court had erred in its finding that a relationship of employer and employee existed between the respondent No.1/claimant and the respondent No.2/owner of the vehicle

Final Decision

The High Court dismissed the appeal and confirmed the compensation award of Rs.3,49,290 with 6% interest from accident date

2026 LawText (KAR) (01) 41

Miscellaneous First Appeal No.3533 of 2018 (WC)

2026-01-21

Hon'ble Ms. Justice Tara Vitasta Ganju

HC-KAR NC: 2026:KHC:3749

Sri. Pradeep B., Advocate for Appellant

SBI General Insurance Company Ltd., represented by its Manager

Mr. Manjunath N (Respondent No.1), Mr. Sanjay Ramesh Sachdev (Respondent No.2)

Nature of Litigation: Appeal against compensation award under Workmen's Compensation Act, 1923

Remedy Sought

Appellant Insurance Company sought setting aside of compensation award of Rs.3,49,290 with 6% interest

Filing Reason

Insurance Company challenged the award contending no employer-employee relationship existed between claimant and vehicle owner

Previous Decisions

Motor Accident Claims Tribunal awarded compensation of Rs.3,49,290 with 6% interest from accident date in E.C.A.No.135/2015

Issues

Whether the learned Trial Court erred in finding that employer-employee relationship existed between claimant and vehicle owner

Submissions/Arguments

Appellant argued no employer-employee relationship existed based on owner's written statement Claimant's evidence established employment as driver with monthly wages of Rs.10,000 Owner denied relationship but failed to appear for evidence or produce contrary proof

Ratio Decidendi

When employer denies employment relationship but fails to lead evidence to substantiate the denial, the claimant's unrebutted testimony establishes the employer-employee relationship for compensation purposes under Workmen's Compensation Act, 1923

Judgment Excerpts

The issue that arises before this Court is, whether the learned Trial Court had erred in its finding that a relationship of employer and employee existed between the respondent No.1/claimant as well as the respondent No.2/owner of the vehicle P.W.1 in the examination-in-chief clearly set out that the injury was sustained by him during the course of his employment and that he was employed by respondent No.2/owner of the vehicle The learned Trial Court has held that since no evidence was led, there existed a relationship of employer and employee between the respondent No.1/claimant and respondent No.2/owner

Procedural History

Claim petition filed under Section 22(1) of Workmen's Compensation Act, 1923 -- Tribunal awarded compensation on 22.01.2018 -- Insurance Company filed appeal under Section 30(1) of Workmen's Compensation Act, 1923 -- High Court heard appeal on 21.01.2026

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