The Supreme Court has clarified that the section 304-A of I.P.C. is applicable only when death is caused due to rash and negligent act of the accused, which is an essential element to attract said provision.
The requirement of section 304-A of I.P.C. is that; death of any person must have been caused by the accused doing any rash or negligent act. In other words, there must be conclusive proof that the rash and negligent act of the accused was the proximate cause of death.
In Empress of India v. Idu Beg13, Straight J., explained the meaning of criminal rashness and criminal negligence in the following words: criminal rashness is hazarding a dangerous or wanton act with the knowledge that it is so, and that it may cause injury but without intention to cause injury, or knowledge that it will probably be caused. The criminality lies in running the risk of doing such an act with recklessness or indifference as to the consequences. Criminal negligence is the gross and culpable neglect or failure to exercise that reasonable and proper care and precaution to guard against injury either to the public generally or to an individual in particular, which, having regard to all the circumstances out of which the charge has arisen, it was the imperative duty of the accused person to have adopted.
Your defense should be on the following lines :
1) Demonstrating that the employment terms, nature of work, safety practices prevalent at work place are well established, published and employees are well aware and acquainted with the facts thereof. (including the deceased) .
2) That the workers are aware and Knowledgeable that non adherence to safety procedures will result in greivous injuries including death.
3) That the accident was a result of negligence by the employees OR unforeseen or uncomprehendable.
4) An accident may lead to death but that an accident had taken place must be proved. Only because a death has taken place in course of employment will not amount to accident. In other words, death must arise out of accident. There is no presumption that an accident had occurred.
More so since you have already paid the compensation to the worker, you have demonstrated your good intentions and also proven.
So if the defense is on the lines that the episode was an accident and it was not a case of NEGLIGENCE OR RASHNESS, in my view, you will win the case for sure.