In a recent decision impacting Québec employers and workers, the Court of Appeal of Québec clarified the scope of work-relatedness necessary for an injury to be compensable under the Act respecting industrial accidents and occupational diseases (LATMP). The ruling, Succession Lares Batzibal v. Les Cultures Fortin Inc., 2025 QCCA 940, has far-reaching implications for both employers and employees, particularly regarding injuries that occur outside regular working hours or during activities that straddle the line between personal and professional life.

Quick Hits

• The Court of Appeal of Québec reversed both the Administrative Labour Tribunal (TAT) and the Superior Court decisions below it, finding that a farmworker’s fatal accident had happened “in the course of work” even though it occurred outside regular working hours.
• The majority stressed that the phrase “in the course of work” under the Act respecting industrial accidents and occupational diseases must be interpreted broadly and liberally to advance the social purpose of the workers’ compensation regime.
• Employers may face increased claims or higher premiums due to the broader interpretation of “in the course of work” by the Court of Appeal of Québec, which could encompass injuries sustained during activities of a seemingly personal nature, particularly when such activities support or benefit work-related equipment or operations.

Background

A seasonal agricultural worker from Guatemala was fatally injured while...

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