Case Brief: C. Manjamma v. The Divisional Manager

INTRODUCTION

“The case of C. Manjamma vs The Divisional Manager, The Oriental Insurance Company Ltd.,” decided by a Division Bench of the Supreme Court of India consisting of “Justices Hemant Gupta” and “V. Ramasubramanian” on March 29, 2022, is a seminal exposition of the principles of the Employee’s Compensation Act, 1923, specifically regarding the interpretation of the expression “arising out of and in the course of employment. This 2022 Supreme Court appeal considered whether the death of a Karnataka State Road Transport Corporation (KSRTC) cleaner-cum-helper, Hanumanthappa, from a snakebite while sleeping at a temporary shelter within the employer-provided depot premises, was compensable under the Employee’s Compensation Act, 1923. The High Court had reversed the Commissioner’s award of compensation. The nub of the issue was the interpretation of “arising out of and in the course of employment” in a case where the fatal accident occurred within the workplace but outside active working hours. The Supreme Court’s ruling dealt with the extent to which the employer’s premises could be said to be within the “course of employment,” particularly when accommodation is provided due to the nature of work and distance of residence. The case turns on establishing a sufficient nexus between the conditions of employment and the unforeseen fatal occurrence. 

FACTS

“The factual context of C. Manjamma vs The Divisional Manager is important to the understanding of the Supreme Court’s rationale. Hanumanthappa, the deceased, worked for the Karnataka State Road Transport Corporation (KSRTC) as a cleaner-cum-helper at their Sindhanur Depot. The character of his work most likely consisted of tasks associated with the maintenance and upkeep of the transport vehicles and the depot facility. One of the key features of his work was the logistical difficulty created by the distance between his permanent location and the Sindhanur Depot. To mitigate this, KSRTC, as employer, arranged temporary accommodation within the depot compound for Hanumanthappa and other workers in similar positions. This accommodation provision emphasizes an implied duty or at least a facilitation by the employer for the workers to stay close to their workplace, indicating that their uninterrupted presence was desirable or needed for the effective conduct of their work.

On the ill-fated evening of August 14, 2007, Hanumanthappa was lying sleeping outside this temporary hut. The reasons why he slept outside are not clearly outlined in the excerpt of the Supreme Court’s judgment but would reasonably be assumed to include such factors as weather conditions (it may have been too hot or humid indoors), insufficient space within the shelter to comfortably fit all the workers, or personal choice. During sleep, he was bitten by a snake, a poisonous reptile whose presence on the depot premises, although possibly not directly connected to the central operating activities of KSRTC, was a potential threat in the work environment. Sadly, the snakebite was fatal, and Hanumanthappa died prematurely.

After this sad event, his widow, C. Manjamma, legally claimed compensation under the Employee’s Compensation Act, contending that her husband’s death occurred out of and in the course of his employment. The Commissioner for Employee’s Compensation, considering the special facts of the case – the accommodation arranged by the employer within the workplace and the presence of the employee there because of his employment – initially held in favor of C. Manjamma and granted compensation. This ruling recognized a connection between Hanumanthappa’s work and the deadly accident.

This award was, however, appealed by The Divisional Manager of The Oriental Insurance Company Ltd., KSRTC’s insurer, to the High Court of Karnataka. The High Court took a narrower definition of the “course of employment” and set aside the order of the Commissioner. The reasoning of the High Court was probably based on the fact that sleeping was not involved in Hanumanthappa’s professional duties as a cleaner-cum-helper and that a snakebite was an incidental occurrence unrelated to his particular job. This split of opinion between the Commissioner and the High Court raised the seminal legal issue regarding how widely or narrowly the “course of employment” should be interpreted, particularly in cases relating to incidents which occur within the workplace but not during active working hours. Intervention by the Supreme Court was necessitated to decide this conflict and clarify the applicability of the Employee’s Compensation Act in these kinds of cases.

ISSUE RAISED

The major issues raised were:

1. Did the workman’s death, which resulted from snakebite while resting outside a temporary shelter arranged by the employer on the workplace premises, occur “out of and in the course of employment” as interpreted under the Employee’s Compensation Act, 1923?
2. Did the employment of the workman exist in a real nexus with the accident that killed him to render him entitled to compensation under the Act?
3. Did the High Court err in ordering the setting aside of the Commissioner for Employee’s Compensation’s order?

PETITIONER’S ARGUMENTS

The learned counsel for C. Manjamma argued that:

1. The deceased was required to stay at the workplace due to the nature of his employment and the distance of his residence.
2. The temporary shelter was provided by the employer within the depot premises, making it an extension of the workplace.
3. Sleeping outside the shelter was a necessity due to the weather conditions or lack of adequate space inside, and it was a reasonable act incidental to his employment.
4. The risk of snakebite, though not directly related to his cleaning duties, was enhanced by the fact that he was required to stay and sleep within the employer’s premises.
5. The incident occurred within the precincts of the workplace and during a time when the workman was compelled to be there due to his employment.

RESPONDENT’S ARGUMENTS

The learned counsel for the respondent argued that:

1. The snakebite was an act of nature and not directly connected to the workman’s duties as a cleaner-cum-helper.
2. The incident occurred while the workman was sleeping, which is not part of his work duties.
3. The risk of snakebite was a general risk and not specifically attributable to the nature of his employment.
4. The death did not arise “out of” employment as there was no causal link between the work he performed and the snakebite.
5. The High Court had correctly set aside the Commissioner’s order as the incident did not occur during the course of employment.

JUDGEMENT

The Supreme Court granted the appeal and overruled the High Court’s judgment, thus reinstating the award of compensation made by the Commissioner. The Court held that the workman’s death caused by a snakebite in the circumstances before the Court did occur “out of and in the course of employment.”

The Court’s reasoning was that:

1. The definition of “in the course of employment” not only extends to the work hours but also to the time when the employee is within the premises of the workplace because of his employment duty.
2. The temporary housing facility provided by the employer within the work premises was a term of employment due to the need for the workmen to remain near their workplace.
3. Night sleeping on the employer’s premises was a reasonable requirement and incidental to the employment, particularly in light of the nature of the work and the distance of the employee’s home.
4. The Court used the “notional extension” theory, which extends the course of employment to cover activities reasonably incidental to it, even though they take place outside the strict working hours.
5. The hazard of snakebite, though may be a universal risk, was enhanced for the workman in that he was forced to live and sleep inside the possibly unsafe environment of the depot grounds in accordance with his job. There was a causative link between the work and the injury.

CONCLUSION 

The Supreme Court ruled that the High Court erred in determining that the death of the workman did not take place “arising out of and in the course of employment.” The Apex Court held that a liberal and purposive construction must be given to the provisions of the “Employee’s Compensation Act”, especially considering its beneficial and welfare-minded character. That the deceased workman had to stay at work, and that the accident had happened on the employer’s premises, created a **reasonable and proximate nexus** between employment and the sad event leading to his death.

The Court explained that the test is not limited to active duty but must take into consideration the totality of circumstances, including whether the presence of the employee at the location was related to the terms of employment. As the death occurred when the employee was legally present on the workplace premises and was carrying out a reasonable expectation of his employment, the nexus to employment was strong enough. Consequently, the appeal was granted, and the initial compensation awarded by the Commissioner was restored in its entirety. This ruling supports the rule that the words “arising out of and in the course of employment” are to be construed widely to encompass accidents which happen on rest breaks or waiting time at the workplace, particularly were staying at the premises is part of the requirement of the employment.