Mackinnon Mackenzie & Co. (P) Ltd. v. Ibrahim Mahmmed Issak
Rule established
If the strain of work is a contributing cause to a heart attack, the injury arises out of employment. Employment need not be the sole cause; contribution is sufficient.
Facts
- Worker employed by Mackinnon Mackenzie (shipping company)
- Suffered a heart attack during working hours at the workplace
- Had a pre-existing heart condition
- Employer argued:
- Heart attack was due to personal illness (coronary artery disease)
- Not caused by employment
Issue
- Whether a heart attack suffered during employment "arises out of" employment when the worker has a pre-existing heart condition but work strain contributed to the attack.
Held
- If work strain is a contributing cause to the heart attack, the injury arises out of employment
- Employment need not be the sole cause; contribution is sufficient
- Pre-existing condition does not defeat the claim
- The test: did the exertion, strain, or conditions of employment contribute to or accelerate the cardiac event?
- Compensation payable
Ratio Decidendi
Where the strain of work is a contributing cause to a heart attack, the injury arises out of employment. The employer cannot defeat the claim by showing the worker had a pre-existing condition. Employment need not be the sole or dominant cause; any material contribution suffices.
How to use it in an exam
- The leading Part C authority on heart attack at work
- Exam pattern: "Worker suffers heart attack during employment. Employer says personal illness. Advise."
- Structure: State ratio (contributing cause test), cite Mackinnon Mackenzie, apply (was there work strain?), conclude (compensation payable if work contributed)
- Key line: "In Mackinnon Mackenzie v. Ibrahim (1970), the Supreme Court held that if work strain is a contributing cause to a heart attack, the injury arises out of employment, and the employer cannot plead the worker's pre-existing condition as a defence."
Source
Source: AIR 1970 SC 1906
This is an educational summary, not the judgment itself. Cite the reported version in professional or academic work.