Employer liability in the workers compensation law is based on the phrase, which is: arising out of and in the course of employment. The phrase establishes the compensability of any injury that an employee had sustained and consequently takes a pivotal role in the employment injury jurisprudence. The term has two aspects the causal relationship between employment and injury and time place and circumstances in which the injury takes place. Courts have over the years considered this phrase as being interpreted in terms of different legal principles like the test of increased risk, positional risk doctrine, actual risk doctrine, personal comfort doctrine and doctrine of notional extension. This has however not been unanimous during judicial interpretation leading to discrepancies in compensation rulings. The issue has now multiplied with the current employment practices like working remotely, other flexible working arrangements, employer sponsored activities, commuting accidents and psychological harm. This paper uses a doctrinal and analytical method to explain the judiciary interpretation and finding patterns and inconsistencies in case law. The paper presents that the interpretation by the judicial system has broadened the definition of the injury in employment; however, the lack of statutory evidence still leaves the topic ambiguous. The document suggests a legal elucidation and standardized legal provisions so that there is uniformity, fairness, and predictability on the compensation laws on workers.