High Court of Madras Adjudicates Employer’s Appeal Under Employees’ Compensation Act, 1923 Challenging Compensation Order. Death of Employee from Coronary Artery Disease While on Duty Raises Question of Liability Under the Act.

High Court: Madras High Court Bench: Principal
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Case Note & Summary

The provided judgment text is incomplete and covers only the initial factual background and procedural posture. The appellant, M/s.NLC India Limited (formerly Neyveli Lignite Corporation Limited), filed an appeal under Section 30 of the Employees’ Compensation Act, 1923 against the order dated 23.12.2021 passed by the Employees’ Compensation Commissioner‑2, Chennai in E.C.No.52 of 2018. The first respondent, Smt.M.Latha, wife of the deceased employee Mayavan, had filed a claim petition before the Commissioner stating that her husband, a Senior Technician – Grade I, was on duty in the third shift on 01.12.2017 and was found unconscious the next morning. He was taken to hospital but declared dead. Post‑mortem revealed the cause of death as coronary artery heart disease. The claim was filed seeking compensation from the employer on the ground that the death arose out of and in the course of employment. The Commissioner allowed the claim, directing payment of compensation. The employer appealed, contending that the death was due to natural causes and not employment‑related. The appeal was heard by the High Court of Madras. The available text does not include the court’s analysis, findings, or final decision. Therefore, the ratio decidendi, headnote, and final verdict cannot be extracted from the provided material.

Issue of Consideration

Whether the death of the employee, Mayavan, due to coronary artery heart disease while on duty arose out of and in the course of his employment, entitling his dependants to compensation under the Employees’ Compensation Act, 1923?

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Law Points

  • Whether death from natural disease (coronary artery disease) occurring during duty hours arises out of and in the course of employment under the Employees’ Compensation Act
  • 1923
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Case Details

2026 LawText (MAD) (07) 29

Civil Miscellaneous Appeal No.1556 of 2022 & CMP.No.11544 of 2022

2026-07-21

N. Anand Venkatesh, J

2026:MHC:3063

Mr.N.Nithianandam for appellant; Mr.V.Ajoy Khose for respondents

The Chief General Manager, M/s.NLC India Limited, Mine-1A, Neyveli

1. Smt.M.Latha, W/O.Late Mayavan, Cuddalore District; 2. The State General Secretary, Centre of Indian Trade Unions, Chennai

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Nature of Litigation

Appeal under Section 30 of the Employees’ Compensation Act, 1923 against an order of the Employees’ Compensation Commissioner allowing a claim petition filed by the deceased employee’s wife seeking compensation for death during employment.

Remedy Sought

The appellant/employer seeks to set aside the order of the Labour Commissioner dated 23.12.2021 in E.C.No.52 of 2018 and disallow the compensation claim.

Filing Reason

The employer contends that the death was due to natural causes (coronary artery heart disease) and did not arise out of or in the course of employment, thus they are not liable to pay compensation under the Act.

Previous Decisions

The Employees’ Compensation Commissioner‑2/Deputy Labour Commissioner‑2, Chennai, vide order dated 23.12.2021 in E.C.No.52 of 2018, allowed the claim petition filed by the first respondent, directing payment of compensation.

Issues

Whether the death of the employee, Mayavan, due to coronary artery heart disease while on duty arose out of and in the course of his employment, thereby entitling his dependants to compensation under the Employees’ Compensation Act, 1923?

Judgment Excerpts

This appeal has been filed by the Neyveli Lignite Corporation Limited (for short, the NLC) under Section 30 of the Employees’ Compensation Act, 1954 against the order dated 23.12.2021 passed in E.C.No.52 of 2018 by the Employees’ Compensation Commissioner-2 - Deputy Labour Commissioner - 2, DMS Compound, Teynampet, Chennai-6. The first respondent filed a petition before the Labour Commissioner stating that her husband – one Mr.Mayavan (since deceased) was working as a Senior Technician – Grade I at the NLC; on 01.12.2017, he was on duty in the third shift; on the next day morning at 6 AM, he was found in an unconscious condition; . . . it came to light that the said Mr.Mayavan died due to the effect of coronary artery heard disease.

Procedural History

The first respondent filed a claim petition under the Employees’ Compensation Act, 1923 before the Employees’ Compensation Commissioner-2, Chennai, which was registered as E.C.No.52 of 2018. The Commissioner allowed the claim by order dated 23.12.2021. Aggrieved by that order, the appellant/employer filed the present Civil Miscellaneous Appeal under Section 30 of the Act before the High Court of Madras.

Acts & Sections

  • Employees’ Compensation Act, 1923: Section 30
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High Court High Court of Madras Adjudicates Employer’s Appeal Under Employees’ Compensation Act, 1923 Challenging Compensation Order. Death of Employee from Coronary Artery Disease While on Duty Raises Question of Liability Under the Act.
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