Neutral Citation No. 2026:JHHC:18404-DB p. 1 IN THE HIGH COURT OF JHARKHAND AT RANCHI L.P.A. No. 196 of 2025 (with I.A. 4009 of 2025) Laltu Parira, son of Shri Samir Kumar Parira, aged about 29 years, resident of Village – Kuntudih Narayanpur, P.O and P.S- Chas, District Bokaro, Jharkhand – 827013. ... Petitioner/Appellant Versus 1. The State of Jharkhand. 2. The Jharkhand State Electricity Board, Address: headquarter Engineering Building, Dhurwa, P.O and P.S- Dhurwa, District - Ranchi, Jharkhand-834 004. 3. The Jharkhand Bijli Vitran Nigam Limited, through its General Manager, Address: Engineer’s Building, Dhurwa, P.O & P.S- Dhurwa, District - Ranchi, Jharkhand-834004. ... Respondents/Respondents --------- CORAM: HON’BLE THE CHIEF JUSTICE HON’BLE MR. JUSTICE RAJESH SHANKAR --------- For the Appellant: Mr Siddhartha Singh, Advocate (through VC) Mr Raj Singh, Advocate (through VC) Mr Raunak Sahay, Advocate For Resp.No.1/State: Mr Sahbaj Akhtar, A.C. to A.A.G.-III For Resp. Nos.2&3: Mr Sachin Kumar, Advocate --------- 02/Dated: 23.06.2026 I.A. No. 4009 of 2025 1. Heard Mr. Siddhartha Singh, who appears with Mr Raj Singh and Mr Raunak Sahay for the appellant; Mr Sachin Kumar, learned counsel for the 2nd and 3rd respondents (contesting respondents); and Mr Sahbaj Akhtar, learned A.C. to A.A.G.-III for the 1st respondent-State. 2. This Interlocutory Application seeks condonation of the delay of 230 days in instituting this appeal. Neutral Citation No. 2026:JHHC:18404-DB p. 2 3. We have perused the averments in the interlocutory application, including, in particular, the averments in paragraphs 5, 6 and 8, which referred to the life-threatening ailments and the consequent disabilities concerning the appellant. 4. In paragraph 9, the applicant has referred to the serious physical injuries caused to him due to the fall of a high-tension wire carrying live current. 5. Considering all these aspects, we are satisfied that sufficient cause has been shown. Accordingly, we condone the delay and dispose of I.A. No. 4009 of 2025. L.P.A. No. 196 of 2025 6. At the request of, and with the consent of, learned counsel for the parties, we take up this appeal for final disposal after condoning the delay in its institution. 7. This appeal challenges the learned single Judge’s judgment and order dated 10.07.2024 dismissing the petitioner’s W.P. (C) No. 4492 of 2019 seeking compensation under the provisions of the Jharkhand State Electricity Regulatory Commission (Compensation to Victims of Electrical Accidents) Regulations, 2018 (the ‘Regulations’). 8. Mr Siddhartha Singh, the learned counsel for the appellant, submitted that there is nothing in the Regulations of 2018 to suggest that the same will apply for claims of compensation in respect of accidents that have taken place before 21st December Neutral Citation No. 2026:JHHC:18404-DB p. 3 2018. He submits that the Regulations provide beneficial schemes for victims of electrical accidents, and there is no reason to construe them hyper-technically. 9. Mr Siddhartha Singh has pointed out that the accident in this case occurred on 12.04.2018, due to which the appellant suffered 60% visual disability, though it was incorrectly assessed at 40%. After the accident, the appellant was involved in treatment, inter alia, at Sankar Nethralaya in Chennai. Therefore, a claim was filed on the 30th of July 2019. 10. Mr Siddhartha Singh submitted that the appellant’s claim has been accepted, but compensation of only Rs. 30,000/- has been paid to the appellant instead of Rs. 60,000/- provided under the Regulations of 2018 on a mistaken interpretation that the Regulations of 2018 apply only to accidents that have taken place after 21st of December 2018. He therefore urged that this appeal be allowed and the impugned judgment and order be modified accordingly. 11. Mr Sachin Kumar, the learned counsel for the 2nd and 3rd Respondents, defended the impugned judgment and order based on the reasoning reflected therein. He submitted that the Regulations came into force from the date of their publication in the Official Gazette, i.e. on 21st of December 2018. He submits that such Regulations generally have a prospective effect and, in this case, in terms of Regulation A2: 2.2, are brought into force from the date Neutral Citation No. 2026:JHHC:18404-DB p. 4 of publication in the Official Gazette. He therefore submitted that there is no error in the determination of compensation at Rs. 30,000/-. 12. The rival contentions now fall for our determination. 13. In this case, there is no dispute that on 12.04.2018, the petitioner, who was a passerby, was seriously injured on account of a fall of live, current-laden wire on him. 14. The appellant had alleged that he suffered visual disability to the extent of 60%. However, the medical evidence has certified that the visual disability suffered by the appellant was 40%. This determination is not the subject matter of challenge before us. 15. Therefore, the appellant, by his application dated 30th of July, 2019, applied for payment of compensation under the Jharkhand State Electricity Regulatory Commission (Compensation to Victims of Electrical Accidents) Regulations, 2018. 16. On merits and after evaluating the facts, the appellant’s claim has been accepted. However, the appellant was awarded only Rs. 30,000/-in compensation. 17. The appellant’s case is that, in terms of Regulation 6.2, he was entitled to compensation of Rs. 60,000/-, as his disability was between 40% and 60%. This was, of course, without prejudice to the appellant’s contention that the disability suffered by him was 60%. Neutral Citation No. 2026:JHHC:18404-DB p. 5 18. The learned Single Judge has declined to award compensation of Rs. 60,000/- on the ground that the Regulations have only a prospective effect and apply only to accidents occurring after 21 December 2018. For this, the learned Single Judge referred to Regulation 2.2, which provides that the said Regulations shall come into force from their publication in the Official Gazette, i.e., w.e.f. 21st of December 2018. 19. The said Regulations were enacted by the Jharkhand State Electricity Regulatory Commission. The preamble to these Regulations is important and would shed light on its beneficial character and, consequently, its scope and import. 20. The preamble to the Regulations read as follows: - “A1: PREAMBLE 1.1 The Section 53 of the Electricity Act, 2003 prescribes the specification of suitable measures for- a) protecting the public (including the persons engaged in the generation, transmission or distribution or trading) from dangers arising from the generation, transmission or distribution or trading of electricity, or use of electricity supplied or installation, maintenance or use of any electric line or electrical plant; b) eliminating or reducing the risks of personal injury to any person, or damage to property of any person or interference with use of such property. 1.2 The Sections 57 and 58 of the Electricity Act, 2003 prescribe specification of standards of performance of a Licensee and Neutral Citation No. 2026:JHHC:18404-DB p. 6 liability for payment of compensation as may be determined by the Appropriate Commission to the person affected by a Licensee failing to meet the specified standards. 1.3 The Section 161 of the Electricity Act, 2003 provides for notice of accidents and inquiries, if any accident occurs in connection with the generation, transmission, distribution, supply or use of electricity in or in connection with, any part of the electric lines or electrical plant of any person and the accident results or is likely to have resulted in loss of human or animal life or in any injury to a human being or an animal. 1.4 The Jharkhand Electricity Regulatory Commission has already notified the JSERC (Distribution Licensees Standards of Performance) Regulations 2015, but it does not provide for compensation for injury to human beings or animals or property, in spite of providing for and ensuring their protection and safety being mandatory under the statutes and the statutory rules above referred to. 1.5 The clause 181 (1) of the Electricity Act, 2003 gives power to the State Commission to make regulations consistent with the Electricity Act, 2003 and specify rules generally to carry out the provisions of the Act. 1.6 In exercise of the powers conferred under clause 181 (1) of the Electricity Act. 2003 and all other powers enabling it in this behalf, the Jharkhand State Electricity Regulatory Commission (JSERC) hereby makes the following regulations for grant of compensation to victims of electrical accidents.” 21. The Preamble, including Regulation 1.4, provides that the Jharkhand Electricity Regulatory Commission has already notified the JSERC Neutral Citation No. 2026:JHHC:18404-DB p. 7 (Distribution Licensees Standards of Performance) Regulations 2015. However, it is noted that, despite the notification of these Regulations of 2015, no provision was made for compensation for injuries to human beings, animals, or property resulting from breaches of the prescribed standards. Regulation 1.4 uses the expression “in spite of providing for and ensuring their protection and safety being mandatory under the statutes and the statutory rules above referred to.” 22. Thus, it is apparent that the prescribed standards were already notified in 2015. Because of non-compliance with such mandatory safety requirements, if there are any accidents, it would not be appropriate to hold that the victims of such accidents must not receive the compensation provided under the 2018 Regulations. That does not appear to be the scope and import of the 2018 regulations. 23. In fact, the Regulations themselves acknowledge a serious lacuna: safety standards were prescribed from time to time, but there was no provision to compensate victims for injuries resulting from breaches of those standards. The Regulations therefore remedy this lacuna. The Regulations are, consequently, both remedial and beneficial. In the absence of any clear provision and based solely on regulation 2.2, there is no reason to hold that the compensation amount provided in these Regulations will apply only to electrical accidents occurring after 21 December 2018. Neutral Citation No. 2026:JHHC:18404-DB p. 8 24. Even otherwise, these Regulations warrant a liberal interpretation, given that the scheme enacted therein is for the benefit of victims of electrical accidents, particularly where such accidents are caused by non-compliance with the performance standards prescribed from time to time, including those specified under the 2015 Regulations. 25. In this case, the claim was filed on the 30th of July 2019, when the 2018 regulations were very much in force. Similarly, the claim was also decided much after the 2018 Regulations came into force. As noted earlier, the Regulations nowhere specifically provide that compensation under them should be paid only when the accident occurred before the Regulations came into force, i.e., on 21st of December 2018. 26. This is also not a case in which the claim was filed after an unreasonable delay following the accident. The accident was on 12.04.2018, and the claim was filed on 30th of July 2019. Mr Siddhartha Singh has explained that the appellant, on account of serious injuries suffered by him, had to focus on the treatment rather than pursue his case for compensation. He pointed out that, advisedly, no limitation period is prescribed under the regulations for filing a claim petition. 27. Mr Siddhartha Singh pointed out that the appellant was required to undergo treatment at the Sankar Nethralaya in Chennai. Medical evidence also shows that the appellant has suffered a visual Neutral Citation No. 2026:JHHC:18404-DB p. 9 disability of at least 40% because of this electrical accident, in which a live wire fell on him. This accident obviously had a direct nexus with the non-observance of the safety standards prescribed from time to time. 28. Therefore, upon cumulative consideration of all these circumstances, we are satisfied that this is a case where the appellant should have been paid compensation of Rs. 60,000/- instead of only Rs. 30,000/-. Regulation 6.2 provides that where the disability is between 40% and 60%, a victim of an electrical accident will be paid compensation of Rs. 60,000/-. 29. Accordingly, we allow this appeal, modify the impugned order and direct Respondents 2 and 3 to pay to the appellant additional compensation of Rs. 30,000/- together with compensatory interest @ 7% per annum from the date of filing of his claim petition, i.e. on 30th of July 2019, till actual payment. We further direct that this amount should be paid to the appellant within six weeks from today. 30. The learned counsel for the appellant pointed out that in terms of the liberties granted in paragraphs 8 and 9 of the impugned judgment and order dated 10.07.2024, the appellant has made representations to the 2nd and 3rd respondents. Since we have not set aside the entire impugned order, but only modified it, obviously, the directions in paragraphs 8 and 9 of the impugned order remain. Neutral Citation No. 2026:JHHC:18404-DB p. 10 31. Therefore, if the appellant has made any representations to the 3rd respondent, we direct the 3rd respondent to dispose of such representations as expeditiously as possible, in any event, within two months in accordance with law and on its own merits. 32. The appeal is allowed on the above terms, without an order for costs. Pending interim applications, if any, will not survive and are disposed of. (M. S. Sonak, C.J.) (Rajesh Shankar, J.) June 23, 2026 A.F.R. Manoj/Sharda/Cp.2 Uploaded on 29.06.2026