Daya Kishan Joshi, (2018) 11 SCC 642; Surendra Pandey, (2015) 13 SCC 625; Lord Denning.

“He fell off the roof of the bus accidentally and died. Merely because the deceased was coming down the roof of the bus after having his meal, cannot be considered in isolation and interpreted so myopically to hold that he was off duty and therefore would not be entitled to compensation. In the facts of the present case and the nature of evidence, there was a clear nexus between the accident and the employment to apply the Doctrine of Notional Extension. If the requirement of the deceased to stay with the bus was integrally connected with the efficiency of the service to be provided and the deceased was not present at the bus terminal with the bus in his nature as a member of the public by choice, we see no reason why the Doctrine of Notional Extension of the employment will not be applicable.”

– Hon’ble Justice Navin Sinha, Leela Bai v. Seema Chouhan, [Civil Appeal No. 931 of 2019].

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Saurashtra Salt Mfg. Co. v. Bai Valu Raja, 1958 SCC OnLine SC 131 recognized Theory of Notional Extension. Theory of Notional Extension had its own peculiarities. Was Section 51E of The Employees’ State Insurance Act, 1948 enacted to clarify and set at rest any serious doubt? It is clarificatory in character and will have retrospective effect. It is very clear, the word ‘deemed’ in Section 51E is employed to put beyond doubt a particular construction that hitherto was uncertain.

– Hon’ble Justice K.V. Viswanathan, Davishala v. Oriental Insurance Company Ltd., [Civil Appeal No. 6986 of 2015] decided on 29.07.2025.