Wife Cultivating Husband's Land Can Claim Farmers' Accident Relief: Allahabad High Court

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Published 3 November 2026

Case: Smt. Urmila Devi v. State of U.P. and Ors.
Court: Allahabad High Court
Bench: Justice Alok Mathur
Citation: 2024 LiveLaw (AB) 273
Decided: 3 June 2024
Statutes: Farmers' Accident Insurance Scheme, 2007
Source: LiveLaw

Bottom Line Up Front (BLUF)

In Smt. Urmila Devi v. State of U.P. and Ors., 2024 LiveLaw (AB) 273, the Allahabad High Court on June 3, 2024, held that a wife cultivating her husband's land is a 'farmer' and can claim benefits under the Farmers' Accident Insurance Scheme, 2007, even if the land is not in her name.

Ratio Decidendi · Legal Principle Established

A wife who cultivates her husband's agricultural land is considered a 'farmer' for the purpose of claiming benefits under the Farmers' Accident Insurance Scheme, 2007, irrespective of whether the land is recorded in her name.

Practice & Procedural Impact for Advocates

Advocates should argue for an expansive interpretation of 'farmer' in social welfare schemes to include family members actively involved in cultivation. Litigants should gather evidence of active participation in farming, such as affidavits or witness statements, even if land records are not in their name.

Key Legal Takeaways

1The definition of 'farmer' under the Farmers' Accident Insurance Scheme, 2007, includes family members actively involved in cultivation.
2Ownership of land is not the sole criterion for claiming benefits under the scheme.
3The scheme's objective is to provide relief to agriculturalists and their families, necessitating a liberal interpretation.

The Legal Issue The Allahabad High Court addressed whether a wife, actively engaged in cultivating her husband's agricultural land, could be considered a 'farmer' and thus eligible for benefits under the Farmers' Accident Insurance Scheme, 2007, even if the land records did not reflect her name. The petitioner, Smt. Urmila Devi, sought relief under the scheme after her husband's death, which occurred while he was engaged in agricultural activities. Her claim was initially rejected on the ground that the land was not registered in her name.

Court's Reasoning Justice Alok Mathur, presiding over the case of Smt. Urmila Devi v. State of U.P. and Ors., 2024 LiveLaw (AB) 273, observed that the Farmers' Accident Insurance Scheme, 2007, was a social welfare scheme designed to provide relief to agriculturalists and their families. The Court emphasized that such schemes should be interpreted liberally to achieve their benevolent objectives. It was noted that in many rural households, women actively participate in farming alongside their husbands, even if the land is formally registered in the husband's name. The Court held that denying benefits solely based on the absence of the wife's name in land records would defeat the purpose of the scheme and lead to an absurd outcome, especially considering the joint family system prevalent in India. The Court concluded that a wife who cultivates her husband's land is indeed a 'farmer' for the scheme's purposes.

What Follows The Allahabad High Court allowed the writ petition, quashing the order that rejected Smt. Urmila Devi's claim. The Court directed the District Magistrate, Sitapur, to reconsider the petitioner's application for benefits under the Farmers' Accident Insurance Scheme, 2007, within two months from the date of the order, taking into account the Court's observations.