Introduction:

In Kishori Lal v. State of Uttar Pradesh and Others, the Allahabad High Court delivered a significant judgment emphasizing the welfare-oriented nature of government schemes intended to provide financial assistance to families affected by unforeseen tragedies. The case revolved around the denial of ex-gratia compensation to a man whose wife tragically died from a snake bite while working in an agricultural field. The petitioner approached the High Court after his request for compensation under the State Disaster Relief Fund was rejected by the authorities on technical grounds. The matter was heard by a Division Bench comprising Justice Ajit Kumar and Justice Swarupama Chaturvedi. The Court was called upon to examine whether the dependents of a person who dies due to snake bite are entitled to receive ex-gratia compensation under the State Disaster Relief Fund and whether such a claim can be rejected solely because the post-mortem report failed to conclusively determine the cause of death. The Court carefully examined the government notifications governing the relief scheme and concluded that death due to snake bite is specifically recognized as a circumstance entitling the dependents of the deceased to ex-gratia assistance. The Court observed that the relevant government notification dated 02 August 2018 clearly includes snake bite among the circumstances for which relief can be provided. Furthermore, a subsequent notification issued on 08 July 2021 clarified that claims for compensation should not be rejected merely because viscera reports are unavailable. The Court emphasized that the scheme is intended to function as a welfare measure and should therefore be interpreted in a manner that advances its objective of providing timely relief to affected families rather than denying benefits based on technical or procedural obstacles. Ultimately, the High Court held that the authorities acted incorrectly in rejecting the petitioner’s claim and directed the District Magistrate of Jalaun to disburse the ex-gratia compensation to the petitioner.

Background of the Case:

The case arose from a tragic incident in which the petitioner’s wife lost her life due to a snake bite while she was working in an agricultural field. Snake bites are a serious public health issue in rural parts of India, particularly in farming communities where individuals often work in close proximity to fields and natural habitats of snakes. After the incident, the matter was reported to the authorities, and the standard legal procedures were followed. Witness statements were recorded, an inquest report was prepared, and a post-mortem examination of the deceased was conducted. However, the post-mortem report did not conclusively establish the exact cause of death. Despite this, the witnesses consistently stated that the woman had been bitten by a snake and subsequently died. Additionally, the local revenue officer, known as the Lekhpal, conducted an inquiry and recorded in his report that the death was caused by a snake bite. Based on these facts, the petitioner submitted an application seeking ex-gratia compensation under the State Government’s notification dated 02 August 2018. This notification had extended relief under the State Disaster Response Fund to certain local contingencies, including death due to snake bite. The petitioner believed that his case clearly fell within the scope of the scheme. However, the authorities rejected his claim. The Sub-Divisional Magistrate relied on the inconclusive post-mortem report and stated that since the cause of death could not be definitively established, the ex-gratia payment could not be granted. The petitioner then attempted to raise his grievance through the government’s “Jansunwai Portal,” an online platform designed for addressing public complaints. Unfortunately, this effort also failed, as his complaint was rejected once again. Left with no other remedy, the petitioner approached the Allahabad High Court seeking judicial intervention.

Arguments on Behalf of the Petitioner:

The petitioner argued that the authorities had wrongly denied him the ex-gratia compensation despite clear evidence indicating that his wife had died due to a snake bite. He contended that the government notification dated 02 August 2018 specifically recognized snake bite as one of the contingencies for which relief could be granted under the State Disaster Response Fund. Therefore, once it was established that the death occurred due to a snake bite, the authorities were obligated to grant compensation to the dependents of the deceased. The petitioner emphasized that multiple pieces of evidence supported his claim. Witnesses had stated that the woman had been bitten by a snake while working in the field. Their statements were recorded immediately after the incident and were consistent with each other. Moreover, the Lekhpal’s report also confirmed that the cause of death was snake bite. The petitioner argued that these pieces of evidence clearly established the cause of death. The petitioner further submitted that the authorities had taken an overly technical approach by relying solely on the post-mortem report. He argued that post-mortem examinations in cases of snake bite may sometimes fail to conclusively establish the cause of death, particularly if there is no visible mark of the bite or if the venom leaves minimal physical evidence. Therefore, the absence of a definitive post-mortem finding should not automatically result in the rejection of a compensation claim. The petitioner also relied on the government notification dated 08 July 2021, which specifically addressed issues relating to delays or denial of ex-gratia compensation in snake bite cases. This notification clarified that the absence of viscera reports should not be treated as a valid ground for rejecting claims. Instead, the authorities were instructed to ensure that compensation is disbursed promptly, preferably within seven days. The petitioner argued that the authorities had completely ignored this clarification and had wrongly rejected his claim. He therefore requested the Court to set aside the decision of the authorities and direct them to grant the compensation to which he was legally entitled.

Arguments on Behalf of the State Authorities:

The State authorities defended their decision by arguing that the post-mortem report did not conclusively establish the cause of death. According to them, the medical examination conducted after the woman’s death failed to determine whether the death was caused by a snake bite or by some other reason. In the absence of a definitive medical finding, the authorities believed that it would be inappropriate to grant ex-gratia compensation under the disaster relief scheme. The authorities also suggested that the relief scheme must be implemented carefully to prevent misuse or fraudulent claims. They argued that medical evidence such as post-mortem reports plays an important role in verifying the cause of death and ensuring that compensation is granted only in genuine cases. Therefore, the inconclusive nature of the post-mortem report created uncertainty regarding the cause of death and justified the rejection of the petitioner’s claim. However, the State authorities did not dispute the existence of the relevant government notifications or the fact that snake bite had been included as a contingency eligible for relief under the State Disaster Response Fund.

Court’s Analysis:

The Allahabad High Court carefully examined the relevant government policies and the factual circumstances of the case. The Court first considered the notification issued by the State Government on 27 June 2016, which established the framework for expenditure from the State Disaster Response Fund. This notification laid down the modalities for providing financial assistance in cases of disasters and calamities affecting the public. Subsequently, the Court noted that the State Government issued another notification on 02 August 2018, which specifically included snake bite among the contingencies for which relief could be granted under the disaster relief scheme. The Court observed that this notification clearly recognized that snake bite deaths are a serious concern in certain regions and that families affected by such tragedies require financial support. The Court also examined the subsequent notification dated 08 July 2021. This notification addressed a recurring issue in which claims for compensation were being rejected due to the absence of viscera reports or other technical deficiencies in medical documentation. The Court noted that the 2021 notification explicitly clarified that the absence of a viscera report should not be used as a ground for rejecting a claim. Instead, the authorities were directed to ensure timely disbursement of compensation to the dependents of victims. The Court concluded that the 2021 notification was clarificatory in nature and was intended to reinforce the objectives of the earlier notification rather than introduce a new policy. The Court emphasized that the underlying objective of the State’s policy was to provide timely support to families who lose a member due to such tragic circumstances.

Court’s Judgment:

After examining the facts and the applicable legal framework, the Allahabad High Court held that the denial of compensation to the petitioner was unjustified. The Court observed that the relief scheme for deaths caused by snake bite is a beneficial welfare measure and must therefore be interpreted in a manner that advances its purpose. Rejecting claims on technical grounds would defeat the very objective of the scheme. The Court noted that the witness statements recorded immediately after the incident clearly indicated that the woman had died due to a snake bite. These statements were consistent and there were no discrepancies that could cast doubt on their credibility. Furthermore, the Lekhpal’s report also confirmed the cause of death as snake bite. In light of this evidence, the Court held that the inconclusive post-mortem report alone could not be treated as a sufficient reason to deny compensation. The Court emphasized that welfare schemes must be implemented with sensitivity and fairness. Authorities should not adopt a rigid or technical approach that deprives deserving individuals of the benefits intended for them. Accordingly, the Court directed the District Magistrate of Jalaun to disburse the ex-gratia compensation to the petitioner.