The Punjab and Haryana High Court has affirmed that the Mukhya Mantri Kisan Evam Khetihar Mazdoor Jiwan Suraksha Yojna, 2013, must be interpreted liberally to protect farmers who die in the course of agricultural activities - even when such acts fall outside formal job duties. This ruling reinforces the scheme’s humanitarian intent and sets a critical precedent for claimants in similar rural accident cases.
Background & Facts
The Dispute
The petitioner, Smt. Kamla, sought compensation under the Mukhya Mantri Kisan Evam Khetihar Mazdoor Jiwan Suraksha Yojna, 2013 (2013 Yojna), following the death of her husband, Sh. Ram Kumar, who drowned on 30.07.2024 while attempting to close a canal hole (mogha) at approximately 10:00 PM on his agricultural land in Siwani, Haryana. The canal’s heavy water flow necessitated immediate action to prevent crop damage. The petitioner applied for the statutory compensation of Rs. 5,00,000, but her claim was rejected at two levels: first by the Secretary, Market Committee, Siwani, on 04.02.2025, and subsequently by the appellate authority, Secretary, Haryana State Agricultural Marketing Board, on 27.06.2025.
Key Facts
- The deceased, Sh. Ram Kumar, was a farmer engaged in agricultural activities on his land.
- On 30.07.2024 at around 10:00 PM, he attempted to close a canal hole to prevent waterlogging of his crops.
- He fell into the canal and drowned.
- The Irrigation & Water Resources Department, Siwani, submitted a report on 27.06.2025 stating that closing canal holes was the responsibility of designated Beldars, not farmers.
- The petitioner had no access to official irrigation personnel at 10:00 PM.
- The deceased had no prior history of unauthorized interference with irrigation infrastructure.
- The petitioner submitted medical death certificate, land records, and witness statements supporting her claim.
Procedural History
- 30.07.2024: Incident - death of Sh. Ram Kumar while closing canal hole.
- 04.02.2025: Initial rejection of compensation claim by Secretary, Market Committee, Siwani.
- 27.06.2025: Appellate authority upheld rejection, holding the deceased was not engaged in a covered agricultural operation.
- 16.03.2026: Writ petition filed under Articles 226/227 of the Constitution of India before the Punjab and Haryana High Court.
Relief Sought
The petitioner sought setting aside of the orders dated 04.02.2025 and 27.06.2025, and directed payment of Rs. 5,00,000 as compensation under the 2013 Yojna, along with interest at 6% per annum from the date of death until realization.
The Legal Issue
The central question was whether the death of a farmer while attempting to close a canal hole during agricultural operations, even if not his official duty, qualifies for compensation under Clause 3 of the Mukhya Mantri Kisan Evam Khetihar Mazdoor Jiwan Suraksha Yojna, 2013.
Arguments Presented
For the Petitioner
Learned counsel argued that the 2013 Yojna is a beneficial social welfare scheme meant to protect farmers in the course of agricultural activities. The deceased was acting to safeguard his crops from waterlogging - an integral part of farming. The scheme’s intent is not to impose rigid job descriptions but to cover accidents occurring in the course of agricultural pursuits. The petitioner relied on the principle that beneficial legislation must be interpreted liberally in favor of the intended beneficiaries. The fact that the incident occurred at night, on the farmer’s own land, and in the absence of available officials, made his action reasonable and within the scheme’s contemplation.
For the Respondent
The Additional Advocate General contended that the deceased’s act of closing the canal hole was outside his duties as a farmer and fell under the exclusive responsibility of Irrigation Department officials (Beldars). Since Clause 3 of the Yojna enumerates specific incidents, and the deceased’s death did not fall under any of the listed clauses, the claim was legally unsustainable. The respondent emphasized strict adherence to the enumerated conditions and argued that extending coverage beyond the text would amount to judicial overreach.
The Court's Analysis
The Court observed that the 2013 Yojna was introduced with a clear humanitarian objective: to provide financial security to farming families who suffer loss of life during agricultural operations. The scheme’s language, particularly Clause 3, is not exhaustive but illustrative of common risks faced by farmers. The Court emphasized that the scheme must be interpreted liberally, not technically, to fulfill its protective purpose.
"The State has introduced 2013 Yojna with intent to extend financial assistance on account of death of a farmer in any accident... The benefit should be given to petitioner because farmer had died while attempting to close hole of the canal."
The Court rejected the respondent’s narrow construction that limited coverage only to acts performed under official mandate. It noted that farmers routinely undertake essential maintenance tasks - such as managing water flow, repairing bunds, or clearing drains - without formal authorization, as these are inseparable from agricultural practice. The timing of the incident (10:00 PM) further underscored the impracticality of awaiting official intervention. The Court held that the deceased’s action was an extension of his agricultural activity, directly linked to crop preservation, and thus squarely within the scheme’s spirit.
The Court distinguished the case from those involving purely personal or non-agricultural risks, noting that the canal was adjacent to the farm, the act was immediate and necessary, and the outcome was tragically foreseeable in the context of rural farming conditions.
The Verdict
The petition was allowed. The impugned orders dated 04.02.2025 and 27.06.2025 were set aside. The State is directed to pay compensation of Rs. 5,00,000 to the petitioner within eight weeks from the date of judgment. Interest at 6% per annum shall accrue from 30.07.2024 until actual payment. All pending applications are disposed of.
What This Means For Similar Cases
Agricultural Activities Extend Beyond Formal Duties
- Practitioners may now argue that any act undertaken by a farmer to preserve crops or manage farm infrastructure - such as repairing irrigation channels, clearing drains, or adjusting water flow - constitutes an agricultural operation under the 2013 Yojna.
- The absence of official designation does not disqualify a claim if the act is reasonably connected to farming.
Beneficial Legislation Requires Liberal Interpretation
- Courts will prioritize the scheme’s intent over rigid textualism when interpreting welfare schemes for farmers.
- Denial of claims on technical grounds, such as "not being the official’s job," will be viewed as contrary to the scheme’s humanitarian purpose.
Night-Time Agricultural Acts Are Covered
- Incidents occurring outside regular working hours, especially in rural areas where officials are unavailable, do not disqualify beneficiaries.
- The timing of the incident (10:00 PM) was deemed irrelevant to the nature of the activity, reinforcing that agricultural work is not confined to daylight hours.
Documentary Evidence Must Be Evaluated Holistically
- Medical reports, land records, and witness statements supporting the farmer’s intent and context must be given weight over bureaucratic reports that ignore ground realities.
- The burden shifts to the State to prove the act was wholly unrelated to agriculture, not to the claimant to prove it was official.
