Gujarat High Court Denies ESI Dependency Benefit In Worker’s Heart Attack Death Case

The Gujarat High Court has held that dependency benefits under the Employees’ State Insurance Act, 1948 cannot be granted unless claimants establish a clear nexus between the employee’s death and the nature of employment.

Justice J. C. Doshi observed that merely suffering a heart attack during working hours does not automatically qualify as an “employment injury” under Section 2(8) of the ESI Act unless credible evidence shows that the employment caused, aggravated, or contributed to the condition.

The ruling came in Employees State Insurance Corporation v. Sudhaben Ramanbhai Patel & Ors., where the ESI Corporation challenged an order of the ESI Court, Ahmedabad, granting dependency benefits to the family of a deceased fitter mechanic.

According to the case record, the employee experienced chest pain during duty hours and later died due to cardio-respiratory arrest caused by coronary heart disease. The claimant argued that the physically demanding nature of the job and workplace stress resulted in the fatal cardiac condition.

However, the High Court found that no medical or corroborative evidence had been produced to establish a direct connection between the employee’s work conditions and the heart attack. The Court held that the burden of proving such a nexus lies entirely upon the claimant.

The Bench further clarified that an injury must arise both “out of” and “in the course of” employment to attract statutory benefits under the ESI Act. Since the required causal link was not established, the Court allowed the appeal filed by the ESI Corporation and denied dependency benefits to the claimants.