Case at a Glance
A Nagpur resident’s son died of a snakebite at Nawagaon Kala in Khairagarh, Chhattisgarh in June 2021. The Tahsildar rejected the father’s claim for ₹4,00,000 natural-calamity assistance because the family lived in Maharashtra, saying the Collector of Nagpur was responsible. Justice Amitendra Kishore Prasad held that the Revenue Book Circular is not confined to Chhattisgarh residents and covers persons who suffer loss in the State. The rejection was quashed and the Collector, Rajnandgaon was directed to pay ₹4,00,000 within 60 days.
Nikesh Chakole died after a snakebite near a hotel at Nawagaon Kala, Tahsil Khairagarh on 14 June 2021; the post-mortem attributed death to snakebite-induced asphyxia. His father, Laxminath Chakole of Nagpur, applied to the Tahsildar on 14 October 2021 for ₹4,00,000 under the State’s scheme for deaths in natural calamities, supported by an affidavit from the deceased’s uncle that the deceased had lived and run the family business at Nawagaon Kala for a considerable period. On 20 June 2022 the Tahsildar rejected the claim because the petitioner lived in Maharashtra and liability lay with the Collector, Nagpur.
The father relied on a State policy of 9 June 2015 providing ₹4,00,000 to the family of a person dying in a natural calamity. The State argued that permanent residence in Chhattisgarh was an essential condition under the Disaster Relief Fund guidelines, and that under the Revenue Book Circular, compensation for a death outside the native district is payable by the district of native residence. It conceded that Clause 5(1) of Part VI of the Circular provides up to ₹4,00,000 for a death from a poisonous snakebite.
The Key Question Before the Court
Can natural-calamity assistance for a snakebite death in Chhattisgarh be refused only because the deceased’s family lived in another State?
Where the Death Happened Matters, Not Where the Family Lives
The Court found that the cause and place of death were undisputed. It held that Note 3 of Part VI of the Revenue Book Circular, which deals with deaths in neighbouring States, had been misread: it provides for Chhattisgarh to grant assistance after obtaining a report, and does not make the Nagpur Collector responsible. “The Revenue Book Circular does not confine for the residents of Chhattisgarh State only,” the Court said.
Relying on Section 20 CPC, Article 226(2) of the Constitution and State of Goa v. Summit Online Trade Solutions (P) Ltd., (2023) 03 SC CK 0035, the Court held that “The occurrence of the incident within the State of Chhattisgarh is a material fact” and that “the cause of action arose in the State of Chhattisgarh”. “The mere fact that the deceased belonged to a State other than the State of Chhattisgarh” could not by itself decide entitlement, and the authority had rejected the claim without examining the Circular at all.
What the Court Actually Held
- The Revenue Book Circular providing assistance for snakebite deaths is not limited to residents of Chhattisgarh; it covers persons who suffer the loss within the State.
- The cause of action arose in Chhattisgarh because the death occurred there; the deceased’s residence elsewhere is not decisive.
- The Tahsildar’s order of 20 June 2022 rejecting the claim on the ground of residence in Maharashtra was quashed.
- The Collector, Rajnandgaon must pay ₹4,00,000 to the deceased’s family within 60 days, verifying only the identity of eligible recipients, without reopening entitlement.
Why This Judgment Matters
- Snakebite deaths are common in rural India; the ruling protects families of migrants and visitors who die away from home.
- It stops authorities from passing the buck to another State’s officials.
- It limits post-judgment verification to identity, preventing fresh delays.
What Should Advocates Take Away From the Judgment?
For Families
- Keep the post-mortem report and panchnama; they prove the cause and place of death.
- Apply in the district where the death occurred, even if you live in another State.
- Affidavits about the deceased’s stay and work at the place can support the claim.
For Counsel
- Challenge rejections based only on residence; the Circular’s text and the place of death control.
- Use Summit Online Trade Solutions to establish territorial jurisdiction where the incident occurred.
- Ask the court to confine verification to identity so the payment is not delayed.
Key Takeaways
- Snakebite relief cannot be refused merely for out-of-State residence.
- The place of death gives the cause of action.
- ₹4,00,000 was ordered from the Collector, Rajnandgaon.
- Payment must be made within 60 days.
Frequently Asked Questions
How much assistance is payable for a snakebite death in Chhattisgarh?
The State conceded that Clause 5(1) of Part VI of the Revenue Book Circular provides up to ₹4,00,000 to the nearest family member, and the Court ordered that amount.
Does this apply to other natural calamities?
The case concerned a snakebite death, but the Court’s reasoning on residence and cause of action applies to claims under the same Circular.
Can the authorities reject the claim again after verification?
No. The Court said entitlement is not to be reopened and the claim cannot be rejected because the deceased lived in Maharashtra; verification is limited to identifying eligible recipients.
Conclusion
The Chhattisgarh High Court refused to let a family fall between two States. A death in Chhattisgarh from a recognised calamity entitles the family to the State’s relief, wherever they live.
Practical takeaway: Families of people who die of snakebite or similar calamities away from home should claim relief in the district where the death occurred; residence elsewhere is not a ground for rejection.
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