Court Emphasizes Beneficial Interpretation of Covid-19 Death Compensation Scheme, Holding Death Within 45 Days of Covid-19 Infection as Covid-Related
In a significant judgment dated August 24, 2026, the Madras High Court, presided over by Mr. Justice C. Kumarappan, ruled in favor of the daughters of a deceased employee of the Food Corporation of India (FCI), directing the respondents to disburse a compensation of Rs. 15,00,000 under the Covid-19 Death Compensation Scheme. The case arose from the death of Mr. G. Johnson, who tested positive for Covid-19 on May 31, 2021, and died on July 15, 2021, within 45 days of his infection.
The petitioners, daughters of Mr. Johnson, contended that his death was due to Covid-19 complications despite the death certificate citing "cardiac arrest" as the immediate cause of death. The medical certificate did not explicitly mention Covid-19, but the petitioners produced a death report indicating Covid-19 as the cause of death, along with references to Government of India circulars and Supreme Court guidelines issued posthumously, which recommend a liberal interpretation in favor of beneficiaries in Covid-19 compensation claims.
The respondents argued that since the medical certificate did not list Covid-19 as the cause of death and the deceased had recovered from Covid-19 before his demise, the compensation claim was not valid. They highlighted that the deceased was discharged from the hospital on June 10, 2021, and died over a month later on July 15, 2021, which, according to their submission, falls outside the Covid-19 death criteria.
However, the Court examined scientific data from the Indian Council of Medical Research (ICMR) establishing that 95% of Covid-19 related deaths occur within 25 days of testing positive, and noted that Mr. Johnson was discharged while his infection persisted, with instructions for continued quarantine and medical review that he reportedly did not follow up on due to systemic healthcare constraints during the pandemic's second wave.
Crucially, the Court emphasized the principle of liberal construction of beneficial or remedial legislation and schemes, especially those intended for social security and relief during the unprecedented Covid-19 pandemic. It held that when two interpretations are possible-one favoring the beneficiary and another favoring the denying party-the interpretation favoring the beneficiary must prevail.
Citing precedents from the Supreme Court of India, including Maniben Maganbhai Bhariya Vs. District Development Officer (2022) and Urmila Dixit Vs. Sunil Sharan Dixit (2025), the Court reiterated the necessity to construe social security laws with the widest possible meaning to fulfill their humanitarian objectives.
Accordingly, the Court granted a writ of mandamus directing the Food Corporation of India to sanction and pay the compensation within four weeks, with an additional 6% interest on delayed payments from the date of the order until actual disbursal.
This judgment reinforces the judiciary's supportive stance towards employees and families affected by Covid-19, ensuring that bureaucratic technicalities do not frustrate the social welfare intent of Covid-19 relief schemes.
Bottom Line:
Covid-19 Death Compensation - Beneficial schemes for Covid-19 deaths must be interpreted liberally and purposively - If two views are possible, the one favoring the beneficiary should be adopted.
Statutory provision(s):
Government of India Circular No.24-2020-16 dated 11.04.2020, Office Memorandum dated 03.09.2021, Guidelines pursuant to Supreme Court orders in W.P. (Civil) Nos. 539 and 554 of 2021, Indian Council of Medical Research (ICMR) studies, Principles of Beneficial Interpretation in Social Security Laws.
