Kamal Dev Prasad v. Mahesh Forge: Supreme Court on Workplace Injury Compensation

Introduction

In Kamal Dev Prasad v. Mahesh Forge (2025), the Supreme Court adjudicated a crucial issue regarding compensation quantification for workplace injuries under the Employees' Compensation Act, 1923.

The Issue

The case examined whether statutory disability percentages in the Schedule can be rigidly applied when multiple injuries cumulatively affect an employee's functionality beyond individual percentages.

The Court's Approach

• Cumulative Assessment: Multiple injuries must be assessed cumulatively, not individually
• Functional Impact: Focus should be on actual functional disability
• Liberal Interpretation: Beneficial legislation should be interpreted liberally in favour of workers

Implications for Employers

Employers must ensure comprehensive compensation for workplace injuries, considering cumulative impact rather than mechanical application of individual disability percentages.

Worker Protection

This judgment strengthens worker protection by ensuring compensation reflects actual disability and loss of earning capacity.