Supreme Court Restores Workmen’s Compensation Award After Holding That High Court Cannot Reverse Well-Reasoned Findings on Employer–Employee Relationship Based on Misreading of Evidence

Held: The Supreme Court held that once the Commissioner for Workmen’s Compensation records a finding of employer–employee relationship based on correct appreciation of evidence, including categorical admissions of the vehicle owner, the High Court cannot interfere merely by relying on an earlier denial in pleadings or by misreading the record, and such interference amounts to a patent error of law.

Summary: The appellant, widow of the deceased driver, filed a claim under the Workmen’s Compensation Act, 1923 after her husband died in a road accident while driving a car in the course of employment. The Commissioner, relying on oral and documentary evidence and the owner’s admission during cross-examination, held that the deceased was employed as a driver and that the accident arose out of and in the course of employment, awarding compensation with interest. The High Court reversed the award by relying on the owner’s initial denial in the counter-affidavit and by incorrectly recording facts regarding the FIR. The Supreme Court examined the entire evidentiary record, including a subsequent affidavit filed by the owner admitting employment and acknowledging that the earlier denial was made to avoid liability, and found that the High Court had completely misdirected itself in law and on facts.

Decision: The appeal was allowed, the judgment of the High Court dated 22.03.2022 was set aside, the award dated 30.04.2009 passed by the Commissioner for Workmen’s Compensation granting compensation of Rs. 3,73,747/- with interest at 12% per annum was restored, and the appellant was permitted to withdraw the balance compensation amount lying deposited with the High Court within four weeks, with all pending applications disposed of.