Inconclusive Post-mortem Cannot Deny Ex-gratia for Snakebite Deaths: Allahabad HC

Justice Over Technicality: Allahabad HC Directs Compensation for Snakebite Victims

In a significant ruling aimed at preventing the "hyper-technical" denial of state welfare benefits, the Allahabad High Court has ruled that bereaved families cannot be denied ex-gratia compensation for snakebite deaths simply because a post-mortem report is inconclusive or a viscera report is missing.

The Division Bench, comprising Hon’ble Justice Ajit Kumar and Hon’ble Justice Swarupama Chaturvedi , emphasized that welfare schemes must be interpreted through a "purposive and liberal" lens, rather than being discarded due to procedural gaps in medical reporting.

A Quest for Relief Met with Red Tape

The case involved Kishori Lal, whose wife, Smt. Raj Kumari, died on August 23, 2019, after being bitten by a snake while working in an agricultural field. Despite immediate police records, an inquest report, and subsequent site inspections by local officials—all confirming the cause of death as snakebite—the state authorities repeatedly denied the family the ₹4,00,000 ex-gratia payment.

The denial was primarily grounded in the post-mortem report, which failed to explicitly record a cause of death, and the fact that the state government’s specific clarification regarding the non-necessity of viscera reports for snakebite claims was issued in 2021—two years after the incident.

The Court’s Reasoning: Clarifying the Spirit of the Law

The High Court rejected the state’s contention that the 2021 clarificatory order could not be applied retroactively to a 2019 death. Writing for the Bench, Justice Swarupama Chaturvedi noted that the 2021 notification was essentially "declaratory" in nature.

"It is a well-established principle of administrative law that subsequent instructions, circulars, or notifications can be used as clarificatory aids in interpreting an earlier policy," the Court observed. By clarifying that viscera examination is irrelevant for certifying snakebite deaths, the state was not creating a new right but merely ensuring the original 2018 notification functioned as intended.

The Court further criticized the authorities for ignoring abundant contemporaneous evidence. When medical evidence is inconclusive, officials are duty-bound, under the principle of contemporanea expositio , to rely on consistent recordings—such as police General Diary entries, inquest proceedings, and eyewitness statements—that support the claim.

Key Observations

The judgment serves as a sharp reminder that state remedies are not intended for mere "academic discourse." The Court remarked:

• "Where the medical report did not negate the version of eyewitnesses, the consistent and corroborated statements of eyewitnesses deserved due weight."
• "While determining entitlement under the scheme, rejection based on technicalities would be antithetical to the very aim and object sought to be achieved by the State."
• "The postmortem report, though inconclusive, does not contradict these records. Therefore... consistency of statements indicate that they are reliable evidence."
• "If a case deserves relief, it must be granted then and there, unflinchingly if need be. Balancing of equities is not to be confused with avoiding or postponing the relief."

A Shift Toward Efficiency

Citing the Supreme Court’s recent focus on judicial efficiency, the Allahabad High Court opted to dispose of the matter directly rather than remanding it for endless bureaucratic cycles. The District Magistrate of Jalaun has been ordered to process the compensation within six weeks.

This decision sets a vital precedent, reinforcing the idea that for welfare measures to be effective, they must be "simple, effective and efficient." Government departments across the state are now effectively barred from using missing forensic reports as a shield against rightful compensation for victims of state-notified disasters.