Case Brief: C. Manjamma v. The Divisional Manager

CASE NAME	“C. Manjamma v. The Divisional Manager”
CITATION	2022 SCC OnLine SC 421
COURT	Supreme Court of India
BENCH	“Justices Hemant Gupta and V. Ramasubramania”
PETITIONER	“C. Manjamma”
RESPONDENTS	“The Divisional Manager”
DECIDED ON	March 29, 2022

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.