Employment LawWorkplace Stress and Cardiac Events: Evolving Standards of Employer Liability in India

INTRODUCTION

In India, due to the enlarged metropolitan influence, the conversation over worker welfare has expanded well beyond pay and working conditions. The unseen toll on the human body increases along with job profiles and expectations in factories, offices, plantations, and tech parks. While incidents like slips or broken machinery demand legal action, heart attacks are a less obvious but growing threat. This raises an important question: is a heart attack just a health issue, or can it be treated as a workplace injury? And if an employee dies from a heart attack at work, can their family get compensation?

Our current statutes have only partially addressed this legal, ethical, and economic challenge. It is no longer merely a theoretical one. It is now time to examine if our legal system provides any respite for hearts that fail under the strain of work, given India’s ageing workforce, rising urban stress, and persistent underreporting of work-related illnesses.

EXISTING LEGAL FRAMEWORK

1. Definition of “accident” and scope of compensation: The foundation of compensation measures for fatalities or injuries related to employment is the Employee’s Compensation Act of 1923 (previously known as the Workmen’s Compensation Act). Its foundation is Section 3, which establishes two requirements: the death or injury must be the consequence of a “accident,” and it must occur “out of and in the course of employment.” This seems simple until one include cardiac attacks in the equation. In contrast to burns or amputations, cardiac events are internal, frequently pre-existing, and infrequently abrupt, as courts have historically defined “accidents.” A heart attack is not specifically specified in any of the Schedules attached to the Act, which detail specific injuries and occupational disorders.
2. Judicial Innovation: Courts have expanded the definition of “accident” through judicial interpretation. Indian courts increasingly view even internal physiological breakdowns as accidents, if they occur suddenly while an employee is on the job. Heart attacks were acknowledged by the Hon’ble Supreme Court as physiological ailments in Shakuntala Shreshti v. Prabhakar Maruti Garvali, [2007 (11) SCC 668]. Therefore, the existence of an “injury,” which was one of the legislative requirements, was met.

The second requirement is proving that the cardiac event occurred as a result of and during the course of employment. This is where the actual difficulty resides. Courts have innovated in order to close this gap. The Hon’ble Supreme Court established a “triple test” which has subsequently served as a guide for subordinate courts. This test looks for three things – stress or strain at work, a work environment that encourages stress and factors that cause or worsen cardiac events. Despite being revolutionary, this test still needs solid factual support.

For instance, in National Insurance Co. Ltd. v. Balwwa, [1993(2) KARLJ406], the Court granted compensation to a worker who had a heart attack after taking a brief break and unloading stones. In this case, the heart failure was directly related to the strain of physical labour. In a similar vein, a worker who passed out after working a full day on a night shift was found to have died from stress related to his job in Kalyani P. v. The Divisional Manager, Southern Railway, [2004 ACJ 185]. These rulings highlight the increasing legal acknowledgement of the unseen emotional cost of employment.

However, there have also been denials. The Hon’ble Supreme Court determined in Jyothi Ademma v. Plant Engineer, [2006 (5) SCC 513] that merely turning switches did not constitute sufficient stress to cause a heart attack. In this case, the work’s nature was judged to be too little to induce physical discomfort. When an employee took a diversion to take a bath, compensation was refused in Mallikarjuna G. Hiremath., [2010 (1) SCC (CRI) 1034] because it was decided that the death was too unrelated to the employee’s job responsibilities.

Therefore, even while courts are open to interpreting “accident” broadly, they nonetheless demand a direct causative connection between the fatal cardiac event and the working conditions. This is particularly challenging when there are no witnesses, medical records, or recorded overwork all of which are common problems in India’s blue-collar and informal labour markets.

NAVIGATING GREY AREAS IN THE EXISTING LEGAL FRAMEWORK

There is no disputing the statutory silence on stress-induced illnesses like heart attacks, even in light of developing jurisprudence. For physically demanding jobs in manufacturing, textiles, and mining, the original Act was designed. Although the Employee’s Compensation Act, 1923, its present iteration, indicates a wider inclusion of professions, its schedules and definitions have not been revised to matchthe realities of the work force.

The main occupational danger in tech parks, investment banks, and call centres is now mental stress rather than physical exertion. Employers have plausible deniability due to the absence of legal certainty. The majority of claims must rely on court discretion in the absence of an amendment that adds unpredictability, delay, and litigation expenses by making heart attacks (and strokes) compensable events.

Furthermore, the grieving family frequently bears the burden of proof, particularly when it comes to the triple-test. Many times, employees skip routine health exams, which results in no records of pre-existing diseases. Families could find it difficult to obtain shift logs or job descriptions, and sudden heart attacks are frequently unwitnessed. The silence of the law becomes deafening in a situation that is already skewed against them.

WELFARE-ORIENTED PERSPECTIVE

A legislative intervention is long required if India is to genuinely adopt the principles of a welfare state.

• First and foremost, the Employee’s Compensation Act, 1923 needs to be amended to clearly acknowledge cardiac arrest, stroke, and mental health disorders as compensable injuries, particularly if they happen at work or can be linked to it.
• Occupations from contemporary industries where long hours and performance stress are common, like IT, BPOs, media, and logistics, should be added to Schedule I of the Employee’s Compensation Act, 1923. This would lessen judicial inconsistencies and provide claims a clearer path.
• The Employee’s Compensation Act, 1923 needs to be amended to clearly acknowledge mental health disorders, cardiac arrest, and stroke as compensable injuries, particularly if they happen at work or can be linked to it.
• Finally, adjudicating authorities under the Act such as Commissioners should be given medical panels and psychological experts to better assess such claims. This would help standardise decisions and ensure fairness.

As it stands, our legal system has done a good work of expanding definitions and extending justice in certain situations. It is unsustainable to rely solely on sporadic case law and lenient judges in a nation with one of the biggest labour forces in the world. Employees and their families are entitled to compassion, clarity, and predictability.

The conversation around cardiac events and compensation is not just about medical science, it’s about recognising the invisible burden that labour carries. The law must now see the heart not just as an organ, but as a measure of how just, inclusive, and responsive our labour system really is.

AMLEGALS REMARKS

The Indian judiciary has commendably broadened the interpretation of “accidents” to include stress-induced cardiac events, acknowledging the evolving nature of workplace injuries. However, this jurisprudential evolution remains constrained by a statutory regime that no longer reflects the realities of modern employment. The Employees’ Compensation Act, 1923, while progressive in its time, falls short in addressing contemporary occupational risks such as chronic stress, burnout, and cardiovascular conditions all of which are increasingly common in today’s fast-paced and mentally demanding work environments.

Labour laws must evolve in tandem with the changing contours of work. A cardiac event at the workplace cannot be dismissed as a mere biological mishap but should be recognised as a potential occupational hazard. Justice demands a framework that not only compensates visible physical injuries but also acknowledges the hidden toll of mental and physiological stress. Structural reform is essential to ensure clarity, consistency, and compassion in protecting the health and dignity of India’s workforce.

–Team AMLEGALS

For any queries or feedback, feel free to reach out to laksha.bhavnani@amlegals.com or mridusha.guha@amlegals.com