Compensation Deposit Alone Sufficient for Appeal Under Employee’s Compensation Act

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  • Last Updated on 11 June, 2026

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Deposit of Compensation for Appeal

Case Details: Executive Engineer-cum-Manager vs. Rukamani Pradhan [2026] 186 taxmann.com 842 (Orissa) [14-05-2026] 

Judiciary and Counsel Details

  • B.P. Routray, J.
  • L. Maharana, Adv. for the Appellant.
  • R.C. Behera, Adv. for the Respondent.

Facts of the Case

In the instant case, a lineman died during the course of his employment, following which his dependents filed a claim under the Employee’s Compensation Act, 1923. The Commissioner awarded them Rs. 8.47 lakh as compensation, along with interest at 12% per annum from the date of the accident until payment.

Aggrieved by the award, the employer decided to challenge it before the High Court under Section 30(1). For filing the appeal, the employer deposited the awarded compensation amount of Rs. 8.47 lakh, but did not deposit the interest amount.

The dependents objected to the appeal, arguing that it was not maintainable because the employer had failed to deposit the entire award, including interest.

The High Court examined whether the term “compensation” in the third proviso to Section 30(1) included interest. The Court held that the statutory requirement is only to deposit the amount of compensation awarded, and that interest is separate from compensation for this purpose.

High Court Held

Since the employer had already deposited the compensation amount, the Court held that the legal requirement for filing the appeal had been met. Accordingly, the dependents’ objection was rejected, and the appeal was allowed to proceed.

For maintaining an appeal under Section 30(1) of the Employee’s Compensation Act, deposit of the awarded compensation amount is sufficient, and the deposit of interest is not a mandatory precondition.

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Author: Taxmann

Taxmann Publications has a dedicated in-house Research & Editorial Team. This team consists of a team of Chartered Accountants, Company Secretaries, and Lawyers. This team works under the guidance and supervision of editor-in-chief Mr Rakesh Bhargava.

The Research and Editorial Team is responsible for developing reliable and accurate content for the readers. The team follows the six-sigma approach to achieve the benchmark of zero error in its publications and research platforms. The team ensures that the following publication guidelines are thoroughly followed while developing the content:

  • The statutory material is obtained only from the authorized and reliable sources
  • All the latest developments in the judicial and legislative fields are covered
  • Prepare the analytical write-ups on current, controversial, and important issues to help the readers to understand the concept and its implications
  • Every content published by Taxmann is complete, accurate and lucid
  • All evidence-based statements are supported with proper reference to Section, Circular No., Notification No. or citations
  • The golden rules of grammar, style and consistency are thoroughly followed
  • Font and size that's easy to read and remain consistent across all imprint and digital publications are applied