Deval Ravidas-Constable [Shivhar District Force]-Member [Static Armed Force], posted at Booth No. 67-Primary School, Mathura Sultanpur-Police Station: Bidupur-District: Vaishali, died due to a sun stroke/heat stroke while performing election duty for Bihar Legislative Assembly.

A proximate causal relationship between an accident and a body injury is necessary [Alka Shukla v. Life Insurance Corporation of India, (2019) 6 SCC 64]. A fatal heart attack while dancing would be called ‘accidental’. But, it would fail to attract insurance cover as it is not due to ‘accidental means’. A heart attack suffered, as a result of over-exertion on being chased by a ferocious dog, might attract insurance cover as it was caused by ‘accidental means’. In our first example, it was a normal activity. In our second example, it was not. In aforesaid context, if present case is analyzed, cause arising from a sun stroke cannot be covered.

– Hon’ble Justice Sanjay Kishan Kaul, National Insurance Company v. Chief Electoral Officer, [Civil Appeal No. No. 4769 of 2022].