The Allahabad High Court delivered a judgment in a case concerning compensation payable to the legal heirs of a deceased farmer under the Mukhyamantri Krishak Durghatna Kalyan Yojana, an Uttar Pradesh State Government scheme intended to provide financial assistance to farmers and their families in the event of fatal accidents. The petition before the High Court challenged the refusal of the District Rural Development Agency to grant compensation under the scheme, on grounds that the Terms and Conditions had not been complied with and that the death did not fall within the defined criteria of a “farm accident” under the policy.
The petitioner, the widow of the deceased farmer, alleged that her husband died as a result of injuries suffered due to an accident while attending to agricultural operations, and that he was therefore eligible for the monetary assistance provided under the scheme. The government respondents, however, contended that the incident did not qualify as a covered event since it did not occur in the immediate course of agricultural work or within the precincts of the farm, as required under the scheme’s definitions. They asserted that the factual matrix of the accident placed it outside the scope of compensation criteria, and justified rejection of the claim.
On examining the materials and the scheme’s provisions, the High Court noted that the Mukhyamantri Krishak Durghatna Kalyan Yojana was promulgated with the object of affording financial security to farmers and their dependents in cases of accidental death so as to mitigate the economic distress caused by such untimely loss of the breadwinner. The Court observed that the scheme must be interpreted in a purposive manner, in light of its humanitarian objective, and that narrow, hyper‑technical interpretations that defeat the welfare purpose should be avoided unless explicitly compelled by the scheme’s language.
The Bench analysed the facts of the case, including the nature of the accident and the circumstances in which it occurred. It recognized that while the accident did not take place within a farm field, the deceased farmer was nonetheless engaged in an activity intimately connected with his agricultural vocation when the incident occurred. The High Court remarked that the test of eligibility under the scheme should focus on whether the farmer was pursuing agricultural work or related tasks at the time of the accident, rather than strictly confining the definition to accidents occurring in a narrowly described physical location.
In this context, the Court highlighted that the purpose of the welfare scheme is to extend relief to farmers who suffer accidental death in the course of activities linked to their livelihood in agriculture, and not to frustrate legitimate claims by applying rigid location‑based criteria that were not intended to be exhaustive. The High Court held that such a purposive reading is necessary to further the scheme’s beneficent goals and to deliver justice to bereaved families who are left economically vulnerable following a tragic accident.
After considering the submissions of both parties, the High Court found merit in the petitioner’s contention that the deceased’s death did indeed qualify as a “farm accident” within the broader purpose and spirit of the Mukhyamantri Krishak Durghatna Kalyan Yojana. Accordingly, the Court allowed the petition, set aside the order rejecting the compensation claim, and directed the competent authority to process and grant the appropriate financial assistance to the petitioner under the scheme without further delay.
The Court’s ruling underscores the principle that welfare schemes designed for socio‑economic support must be interpreted in a manner that advances the policy objective and accords substantive justice to beneficiaries, particularly where rigid literalism would undermine the legislative intent. By adopting a purposive approach to construction of the eligibility criteria, the High Court emphasised that beneficial provisions must not be thwarted by technical exclusions that bear no substantial connection to the scheme’s humanitarian goals. The judgment reinforces the role of courts in ensuring that statutory and executive schemes for social welfare are administered fairly and in alignment with their declared objectives, providing meaningful relief to those for whom such schemes are established.
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