Punjab & Haryana High Court Holds Heart Attack Suffered After Denial of Short Leave Has Causal Nexus With Employment; Allows ESI Death Benefits to Widow

Case Name: Baljinder Kaur v. Employees’ State Insurance Corporation and Another

Date of Judgment: 23 December 2025

Citation: FAO-937-1998

Bench: Hon’ble Mr. Justice Pankaj Jain

Held: The Punjab and Haryana High Court allowed an appeal and held that the death of an insured employee due to cardiac failure, suffered shortly after completion of strenuous duties and denial of short leave despite deteriorating health, had a direct causal connection with his employment. The Court held that where evidence establishes that the employee’s health deteriorated during duty hours and the collapse followed immediately thereafter, the accident must be treated as arising out of and in the course of employment within the meaning of the Employees’ State Insurance Act, 1948. The rejection of dependent benefits by the ESI Corporation was accordingly set aside.

Summary: The appellant, widow of the deceased employee, sought dependent benefits under the Employees’ State Insurance Act on the ground that her husband died due to a cardiac episode having a direct nexus with his employment. The deceased was employed as a kitchen runner and dish washer and had worked continuously on the relevant day. Evidence on record showed that while on duty, his health deteriorated and he requested short leave, which was denied by the management owing to rush of work, requiring him to continue performing physically demanding duties.

The deceased collapsed while returning home on his bicycle shortly after completing his shift and later died in hospital. The ESI Corporation rejected the claim, holding that the death occurred after duty hours and had no causal connection with employment. The ESI Court upheld the rejection by relying on the judgment in Francis De Costa.

The High Court examined the evidence, particularly the testimony of the employer’s senior clerk, which established that the deceased was unwell during duty hours, had sought leave due to illness, and was compelled to continue working. The Court held that the onset of the cardiac condition had occurred during the course of employment and that the subsequent collapse was only the culmination of the same condition.

Applying Sections 2(8) and 51A of the Act, the Court held that once it is shown that the employee’s health deteriorated while performing employment duties and that the fatal incident followed in close proximity, the presumption under law operates in favour of the claimant. The Court distinguished Francis De Costa on facts and held that denial of leave and continued physical exertion provided the necessary causal link between employment and death.

Decision: The appeal was allowed. The order passed by the ESI Court and the rejection by the ESI Corporation were set aside. The respondent Corporation was directed to release all dependent benefits to the appellant in accordance with law, along with interest at the prescribed rate, within the stipulated period.