ALLIANCE SCHOOL OF LAW

LABOUR LAW II
PROJECT REPORT SUBMISSION

TITLE :“Application of doctrine of Notional Extension under Workmen’s

Compensation Act and Employees State Insurance Act”

Submitted by
Anubhav Tiwary

VIKALP SHARMA

Bba.llb.(sec-b)

2015-20 batch - [8thsem]

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 Abstract
The whole purpose of this research is to find out the maximum threshold of protection provided
by the Employer to his workmen under the defined limits of the premises of the Establishment
during his course of employment.

The compensation to the injured worker under the Employee’s State Insurance Act 1948 and
Workmen’s Compensation Act, 1923 is considered according to the Doctrine of Notional
Extension. This doctrine focuses on the course of employment of a worker.

The Research is totally based on the Doctrinal approach which provides that the compensation is
expressly defined under the Workmen’s Compensation Act but not expressly defined under the
Employees State Insurance Act.

The doctrine of notional extension has an important criteria for the fulfillment of compensation
to employees that is there should be a causal connection between place of accident and place of
work. However if the 'casual connection with place of work' gets defined by the Employee's
Compensation Act, through a suitable amendment, by legislature, then executive is to determine
relationship between place of accident and place of work.

The term “arising out of” has been subjected to judicial interpretation from the very beginning.
This term has been coupled with the “arising out of employment”. Even though the meaning of
these two phrases is different then also there is an inseparable connection between them.

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 Table of Contents
INTRODUCTION………………………………………………............................05

1.1. Introduction
1.2. Research Problem
1.3. Existing Legal Situation
1.4. Literature Review
1.5. Scope and Objective
1.6. Research Methodology
THE CONCEPT OF NOTIONAL EXTENSION…………………………………..09

POSITION OF NOTIONAL EXTENSION IN INDIA….........................................12

COMPARATIVE ANALYSIS………………………………………………….…..15

DIFFERENCE OF RELIEF UNDER BOTH THE ACTS………………………….18

CONCLUSION……………………………………………………………………...19

Bibliography

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 1. INTRODUCTION

1.1 Introduction
It is easy to determine that the accident occurred in the course of employment when a workman
is injured in the working place and during the working hour. The actual problem arises when the
accident does not occur during the course of employment or injured in the working place during
the working hours. But if the workman injured near the work premises then the problem arises as
will the employee is entitle for the compensation under workmen’s compensation act and
Employee state insurance act.

According to doctrine of notional extension compensation to be provided to the injured worker

under employee state insurance act 1948 and workmen’s compensation act 1923. This doctrine
signifies the course of employment.

Section 3(1) workmen’s compensation act, 1923 provides that the injury must be caused to
workmen by an accident arising out of and in the course of employment. Employment does not
necessarily ends when the tool down signal is given or when the workmen leave the actual
workshop. There is notional extension as both the entry and exit time and space. As employment
may end or may begin not only when the employee begins to work or leaves his tools but also
when he used the means of access and egress to and from the place of employment.1

It is settled in various case laws and also doctrine of notional extension states the employee is
entitle for the compensation also when is injured outside the working premises when during
coming and going to the place of work. The doctrine of notional extension is being dealt
extensively in case where an employee of M/S electronic product of India, Chandigarh left his
house at about 8:30 am to join his duties at 9:00 am. He died at bus stand while waiting for the
local bus. It was held that the employee died while he was going to his place of work. The theory
of notional extension will apply and the death occurred in the course of employment 2. Doctrine
of added peril is contrary to the doctrine of notional extension as added peril provides the
1
Satyabhavna v ESI Corp.

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benefits to the employer but on the contrary notional extension provides the benefits to the
employee. The notional extension doctrine has a vital advantage to the employees working in an
establishment, in the course of employment and they can duly claim benefits due to the doctrine
of notional extension. Under workmen’s compensation act, 1923 doctrine of notional extension
grants compensation and will be applicable only when there is un-rebutted evidence that the
death of the deceased occurred due to stress and strain during the course of employment3.

It is easy to determine that the accident occurred in the course of employment when a workman
is injured in the working place and during the working hour. The actual problem arises when the
accident does not occur during the course of employment or injured in the working place during
the working hours. But if the workman injured near the work premises then the problem arises as
will the employee is entitle for the compensation under workmen’s compensation act and
Employee state insurance act.

According to doctrine of notional extension compensation to be provided to the injured worker

under employee state insurance act 1948 and workmen’s compensation act 1923. This doctrine
signifies the course of employment.

Section 3(1) workmen’s compensation act, 1923 provides that the injury must be caused to
workmen by an accident arising out of and in the course of employment. Employment does not
necessarily ends when the tool down signal is given or when the workmen leave the actual
workshop. There is notional extension as both the entry and exit time and space. As employment
may end or may begin not only when the employee begins to work or leaves his tools but also
when he used the means of access and egress to and from the place of employment.4

It is settled in various case laws and also doctrine of notional extension states the employee is
entitle for the compensation also when is injured outside the working premises when during
coming and going to the place of work. The doctrine of notional extension is being dealt
extensively in case where an employee of M/S electronic product of India, Chandigarh left his
house at about 8:30 am to join his duties at 9:00 am. He died at bus stand while waiting for the
local bus. It was held that the employee died while he was going to his place of work. The theory

2
Sheela v ESI Corp. 1900 ACJ 476,[1991] ILLJ 247 PH
3
United Indian Insurance company Ltd. v Susheela ILR 2004 KAR 1332, 2004(2) KAR LJ 265
4
Satyabhavna v ESI Corp.

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of notional extension will apply and the death occurred in the course of employment 5. Doctrine
of added peril is contrary to the doctrine of notional extension as added peril provides the
benefits to the employer but on the contrary notional extension provides the benefits to the
employee. The notional extension doctrine has a vital advantage to the employees working in an
establishment, in the course of employment and they can duly claim benefits due to the doctrine
of notional extension. Under workmen’s compensation act, 1923 doctrine of notional extension
grants compensation and will be applicable only when there is un-rebutted evidence that the
death of the deceased occurred due to stress and strain during the course of employment6.

1.2 Research Problem

1.2.1 Whether the doctrine of notional extension has the same applicability under the
Workmen Compensation Act 1923 and Employees State Insurance Act 1948.
1.2.2 What is the position of the concept of notional extension at International level?

1.3 Existing Legal Situation

The current existing legal situation can be easily analyzed under the act of Workmen
compensation Act 1923 and Employees State Insurance Act 1948.
1.4 Literature Review
This topic has been successfully dealt with by various eminent researchers, jurists and authors,
and I respectfully acknowledge their works in the field.
The work of P.K. Padhi,“Labour and Industrial Laws” and it offers a retreat to various facets of
their applicability.
The work of H.L. Kumar, “Compliance under labour law” helps us to examine the territorial
jurisdiction to which the doctrine of notional extension allows to claim benefit under the act.

1.5 Scope and Objective

The Scope of the research is to find the applicability of the doctrine at the International
level as the objective of the governing act is :

5
Sheela v ESI Corp. Ibid
6
United Indian Insurance company Ltd. v Susheela, Ibid

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  To provide workmen and/or their dependents some relief or compensation in case
of accidents arising out of and in the course of employment and causing either
death or disablement(partial or total) of workmen.
 The act extends to whole of India. It applies to workmen employed in factories,
mines, plantations, transport establishments, construction work, railways, ships,
circuses, and other hazardous occupations and employments specified in Schedule
II of the act. The act does not apply to members of armed forces of the Union and
workmen who are covered by the ESI Act 1948.

1.6 Research Methodology

The study has been carried out with a doctrinal approach using the appropriate primary and secondary
sources related to the issue dealt with. The primary sources for the study are the books addressing the
core topic and the judgments delivered and the secondary sources are a few commentaries, blogs
articles and preliminarily extracted factual data.

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 DOCTRINE OF NOTIONAL EXTENSION

The social security system in India is composed of a number of schemes and programs which are
spread throughout a variety of laws and regulations. This system of social security includes
insurance payment of premiums into government funds, pension, gratuity and other employer
obligations. The Employee’s Compensation Act 1923 and the Employee’s State Insurance Act
1948 are one of such legislations which aims at the social security of the employees. These
legislations aims at putting a liability on the employer to pay compensation to the employees or
their families in cases of employment related injuries. In addition, in certain types of
employment, the workers are exposed to the risk of contracting certain diseases which are
peculiar to that type of employment. These legislations puts the liability on the employer to pay
compensation in cases of occupational diseases.

Section 3(1) of the Workmen Compensation Act, 1923 says that –

“If personal injury is caused to a workman by accident arising out of and in the course of his
employment, his employer shall be to pay compensation in accordance with the provision of this
chapter…7” There are three components in the definition which are – (1) personal injury (2)
accident (3) arising out of and in the course of the employment 8. This last point is the key of this
section. With advancement in the field of industry, the workmen have become more insecure
with regard to their employment and as a result of that many social security legislation has come
up. This Act is also among them. The judiciary has also realised this purpose of the act and
interpreted the terms widely and gave birth to doctrine of notional extension. It is not easy to

7
Section 3(1), Workmen Compensation Act, 1923
8
All Answers ltd, 'Legal obligation on employer to pay compensation' (Lawteacher.net, April 2019)
<https://www.lawteacher.net/free-law-essays/contract-law/legal-obligation-on-employer-to-pay-compensation-
contract-law-essay.php?vref=1> accessed 9 April 2019

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determine what is the scope of the term and lay down a test to determine what is “arising out of
employment”. There have been many attempts to construct a proper meaning of this term. A lot
of issues have to be considered like the nature, condition, objects and incidents of employment.
“The words “in the course of the employment” mean “in the course of the work which the
workman is employed to do and which is incidental to it.” The words “arising out of
employment” are understood to mean that during the course of the employment, injury has
resulted from some risk incidental to the duties of the service, when, unless engaged in the duty
owing to the master, it is reasonable to believe the workman would not otherwise have suffered.
In other words, it means that there must be a casual relationship between the accident and the
employment. (State of Rajasthan v.Ram Prasad and another). There have been a number of cases
in which the apex courts have tried to take out the true meaning of the term “in the course of
employment” and through these cases, the ambit of the term has been widened. Using these
precedents and the judgements laid down by the courts, there is no problem in determining that
accident occurred in the course of employment if he is injured at the workplace and at the
working hours and doing hid duty. The real issue arises when all these elements do not coincide
with each other. What if the workmen is injured while he is near the premises of the workplace
or on his way to work? To determine whether the employer is liable to pay the employee in these
circumstances, the theory of notional extension evolved. Earlier, it was generally the rule that the
employment of a workman does not commence until he reached the workplace and comes to an
end as soon as he leaves the workplace. However, now this is subject to the theory of notional
extension as whether to include an area through which the employee passes while going and
leaving his place of work. The doctrine of notional extension provides some reasonable
extension in both time and place in which the employee will be considered to be in the course of
the employment even if he has not reached or left his place of work. It becomes necessary to
examine the facts and the circumstances of each case carefully in order to determine whether the
accident arose out in the course of employment or not. While determining whether the doctrine
of notional extension will be applicable and the accident will be considered to have happened in
the course of employment, it is important to carefully determine the circumstances of each case
and to create a link between the accident that occurred and the employment. It is on the apex
court to understand the facts and situations of the case and decide whether an employee will get
the compensation or not. There was a case in which an employee met with an accident while
travelling in a bus to his place of work. He was not provided with compensation by the
competent authorities. It was held by the apex court that the employee used the bus to travel to

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and fro from his place of work and it was necessary to take the bus everyday to perform his duty
efficiently and punctually. Therefore, travelling in that bus was an implied condition to his duty
and therefore he was provided with compensation as this was considered to be arising out of the
course of the employment. In another case, where a workman was ordered by his employer to go
to another place for cleaning of the railway track and while coming back, the employee was
crossing the railway track and died, it was observed by Hon’ble Justice Shukla that the accident
occurred in the course of the employment as he was ordered by the employer to go to a particular
place, and hence the employer was liable to pay compensation. 9 There are certain exceptions in
which the doctrine of notional extension will not be applicable. One such exception is when a
workman is on public road or public place, not fulfilling any obligation of his workplace, then if
any accident occurs, he will not be entitled to get compensation. The proximity of the workplace
and the spot of the accident becomes immaterial in these cases. It is well settled that when a
workman is on a public road or a public place or on a public transport he is there as any other
member of the public and is not there in the course of his employment unless the very nature of
his employment makes it necessary for him to be there. 10 In later cases, the apex court took a
more liberal stand on expanding the definition of the term notional extension realizing the social
view point and objective of these social welfare legislations11. The doctrine of notional extension
is thus applicable even if the workman has not reached his place of work and he is entitled to
compensation in case an accident happens. The judiciary, through its various judgements have
widened the scope of the doctrine of notional extension and this doctrine has been very helpful
for workmen to get proper compensation under the Workmen Compensation Act and the
Employee State Insurance Act. The most recent judgement regarding the doctrine of notional
extension was passed by the Hon’ble Supreme Court in which it held that the doctrine of notional
extension of employment applies when the accident occurred while the deceased workman was
in workplace not by his own choice12. Therefore the scope of the doctrine of notional extension is
not limited and the judiciary through its various judgements keeps expandoing the scope of the
doctrine for the social welfare of the employees.

9
Union of India v. Mrs. Noor Jahan
10
Saurashtra Salt Manufacturing Co. v. Valu Raja, AIR 1958 SC 881, (1958) IILLJ 249 SC

11
Superintending Engineer, T.N.S.E.B v. Sankupathy (T. M. T.), 2004
12
https://www.livelaw.in/news-updates/doctrine-notional-extension-employment-accident-deceased-workman-
workplace-not-choice-sc--142317

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 POSITION OF NOTIONAL EXTENSION IN INDIA

It is about the compensation to the injured worker under the Employee state Insurance act 1948
and Workman compensation act, 1923 .It basically throws a light on the worker working under
the employment. “The rule says that, the worker is said to be working only when he at the work
place and not out of the work place, the worker travelling for job and for any work is completely
excluded. Its .it is said that now a days the worker travelling for the job and for the work is to be
included for in the course of employment. There is a lot of reasonable things in both time and
place even when he does not the place where he /she actually works Here are some facts of the
case which will help us to understand how in the following case what acutely happened and how
the accident arose out of the course of employment of a worker keeping the view in mind the
doctrine of notional extension. Let’s know before knowing the doctrine what is called as a duty?
The court has given wider and clear meaning to explain what is duty and to expand with its
section.in this the court also talks about the service of contract whether it will come under this
preview of section or not. Justice Cozens-Hardy M.R. said that when some agreement t is done
for the service of contract the thing is the charges which is going to happen should be provided
by the employers and not the employee itself. There is case which is explained below which
clearly states a broader sense of duty it is widely scoped and explained.

CASE:

In Weaver v. Tredegar Iron Coal Co.

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The judges who sat for listening the case said after examining the authorities we have seen that
the duty can be explained as it has a very wider meaning but did not neglected the test. In this
case it is said that the LORD ATKIN the course of employment cannot be limited to the time or
place of a specific for which the workmen is actually employed to do so. It does not completely
end here even if the down tools signals are given or from the workshop from he just left. There
are some reasonable extension in both time and space.

For e.g. it is given by Porter it is said that if the accident happens while the worker is coming to
work at its work place or leaving the work place can be out of in the course of employment if he
is bound by the agreement or any term of contract express or implied here heredity test was
examined and lastly it was confirmed. Here is social point of view it is more liberal and court
also took a very liberal stand in expanding the definition of notional extension realizing the
social point of view and the objective of the act. Here the employee died on its way to while
going to its work place because of communal riot. It was said by the appellant that the person
died before the commencement of the work and outside of the workplace. Basically there is no
connection between the accident and employment. As far it is concerned The High Court of
Madras has neglected all this argument and allowed the compensation.

SECTION 3(2): If a workman employed in any course of employment in part contracts any
diseases or any occupational diseases during employment or if a worker is employed by an
employer not less than six months of employment and in this no other service contract should be
made under the employment. As it goes same with part B and Part C. The central government t
may say that in the respect of such employment the contracting of the diseases should be and the
injury or an accident caused during then it should be deemed under this section, unless the
contrary is proved and the accident should be arisen during the course of employment. Here if it
is proved :

(a) When a worker is employed and is contracted with any diseases specified under the
occupational disease peculiar to the employment during a continuous period which is less
than the period mentioned in the section for that employment.
(b) That the disease is caused and happened during the course of employment, the disease
which have contracted is said to an injury by accident within the, meaning of this section.
If any disease is caued and id proved that a worker who was served under the

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 employment or contract basis and has continuous period as under specified section the
disease is said to be injury by accident within the meaning of this section.

(2A) If a worker is employed in the employment specified under the part of schedule 3 contracts
to any occupational disease peculiar to that employment, the contract is said to be an injury by
accident within the meaning under this section, , and such employment was under more than one
employer, and here all ten employers are liable for the payment of compensation in such a
manner as said by the commissioner may say , and according to the circumstances as it may
deem fit as the situation says.

Here the doctrine of notional extension is not specifically enriched under the Employees State
Insurance Act 1948 or Workmen Compensation Act. The notional Extension is yet to be
amended any one act is to be amended and if any accident happens outside the premises within a
kilometer radius of the workplace and its working hours it will be considered as an employment
injury same logic will be applicable for the acts as workmen act and the other.

If the accident happens in the company provided vehicle, irrespective of the location and time it
is known as the employment injury as per WC Act and ESI Act.

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 COMPARATIVE ANALYSIS

Position in India

Doctrine of notional extension (principle to pay compensation to the injured worker) is

considered under the Employee’ State Insurance Act, 1948 and Workmen’s Compensation Act,
1923.

According to Section 3 (1) of the Workmen’s Compensation Act, 1923, it provides the injury and
it must be caused to the workmen and also arising out of an in the course of employment, also
the course of employment does not ends when workmen leaves the premises of work.
Employment begins when he/she use the means of access to come and go from the place and
premise of work.

According to the rule, the employment of the workmen does not starts until he has reached to the
place of work the time when he left for the place of work and also home from the place of work
is excluded. However, according to doctrine of Notional Extension of the employer’s premises
does include the time when he leaves the place for work as well as leaves for the home after the
employment. The accident arise in the course of employment is determined case to case and
carefully keeping all the principles in mind of Notional Extension.13
13
Sadgunaben Amrutlal and Ors. V The Employee’s State Insurance [1981] 22 GLR 773; Rajappa V Employee
State Insurance ILR 1992 KAR 284

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There are various judgments which has been extracted and discussed by Supreme Court and
High Court where the notional extension theory played an important role is giving the judgment
as they have considered the time where the employee leaves home for the place of work and also
when employee leaves the place for work to go home is considered as the course of employment
and in these conditions mentioned above if he met with an accident then the courts have
considered it as an accident arising out of in the course of employment and in this scenario
employee is entitled for the compensation under the Workmen’s Compensation Act, 1923.

Only in the condition where the there is un-rebutted evidence is there to show the death of the
deceased has occurred due to stress which results in cardiac arrest on his way of work, doctrine
of notional extension under Workmen’s Compensation Act will be applied.

According to Employee State Insurance Act. 1948, if the employee met with accident outside the
place of work within 1 km of the radius from the employer premises during reasonable office
hours will be considered as employment injury. Under, Workmen’s Compensation Act. 1923,
employee cannot ask for the wages for the period he lost, any settlement outside or any payment
made directly to the employee will not be considered as legal compensation. The payment to be
made before the labour commissioner. Applicability of this doctrine is based on the case to case.

Position in U.S.A

Employee is entitle for the compensation under the doctrine of notional extension only if the
injury occurred out of in the course of employment, there should be casual connection between
the injury and work. The burden of proof lies in the hands of employee to prove the risk from the
work or employment.

There are requirement which to be looked before giving the compensation to the worker:

1. Injury must be arises out of employment;

2. In the course of employment;
3. In the employment period.

Location should be reasonable for the course of employment and also employee must fulfill work
duties. Analyzing the injuries that arise out of the course of employment is difficult and

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confusing14. The purpose of workmen’s compensation act is not to protect employee from the
risk of accident. There have been compromised by the courts that the apart from the place of
work employee coming to the employer premise and going home will be considered under
worker’s compensation if the injury occurs for the same. This principle has been discussed in the
case of Heim V. Longview Fibre Co.

Position in U.K

In United Kingdom, if any worker suffers injuries or death due to negligence, carelessness so
their family or worker itself can claim the compensation under worker compensation act in UK.
In the workplaces accident can arise and it is unexpected and among which carelessness is one
the main reason for the cause of accidents.

In UK, government has enacted many laws and rules to ensure safety of the workers and ensure
their safety especially in accident-prone zone.

Basically there are two ways to take benefit of the compensation:

1. Personal injury is occurred to claimant;

2. Arising in the course of employment.
There are many workers who died in the daily journey from and to work, every European
country except UK who does not include the journey from work under the course of
employment. In UK, workers employment starts when he reaches to the employer premises or
place of work.

14
Gregory P Guyton, a brief history of worker’s compensation, [1999]

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 DIFFERENCE OF RELIEF UNDER BOTH THE ACTS

The compensation is expressly defined under the Workmen’s Compensation Act but not
expressly defined under the Employees State Insurance Act.

The principal behind compensation to the injured worker under the Employee’s State Insurance
Act 1948 and Workmen’s Compensation Act, 1923 is considered according to the Doctrine of
Notional Extension. This doctrine throws light on the course of employment of a worker.

This doctrine is contrary to the doctrine of notion extension. While the doctrine of notional
extension benefits to the employee, the doctrine of added peril is for the benefit to the employer.

Therefore, where the injury is not caused to workman by an accident arising out of and in the
course of employment, he/she is not entitled to get any benefit or compensation under the
Employee’s State Insurance Act 1948 and the Workmen’s Compensation Act, 1923.

There exists the Nexus between :

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  Start from home place of residence
 Time
 Shortest route to place of employment

An employee or workman who comes in a public transport for work meets with an accident dies
cannot be said to die in the course of employment as he is one among the public and therefore
the theory of notional extension cannot be applied.

Whereas an employee travelling in a co bus can be deemed to be in the course of employment as

his employment starts from the minute he boards the bus the compensation paid for total
permanent disablement is greater than the compensation for dependent under the death of the
person.

Concluding by saying that the doctrine of notional extension is expressly defined under the
Workmen Compensation Act 1923 but not expressly defined under Employees State Insurance
Act 1948.

CONCLUSION

This doctrine signifies on the course of employment, and also states the employment, as it does
not end once you are out of the work or place of work it includes the area where the workman
comes and goes from the place of work. In India, workmen’s compensation act and employee
state insurance act adopted this principle of doctrine as well as judiciary has adopted principle in
various case laws. Unlike, USA they usually follows the principle of work premise during such
claim as they follows the course of employment only the place of work. According to USA,
injury should take place in the place of work, which shall be considered as the course of
employment. But also, there has been some disputes where the premise rule has been very harsh
so they are planning to extend this rule to reasonable distance of the employer’s premises. In UK,
injury should be caused during the course of employment and course of employment starts from
when the employee comes for the place of work and ends when he leave for the place of work.

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