Korean Administrative Court Recognizes Causation Between COVID-19 Vaccination and Death

On July 11, 2025, the Seoul Administrative Court of Korea rendered a significant judgment (Case No. 2023GuHap73595) recognizing a causal link between the administration of a COVID-19 vaccine and the death of a patient in Korea who suffered from an intracranial hemorrhage. The Korean Court annulled the decision of the Korea Disease Control and Prevention Agency (KDCA) denying compensation under the national vaccine injury relief scheme. This along with the Korean Covid-19 Vaccination Workers’ Compensation Injury Case shows the willing of Korea to infer a nexus between the Covid-19 Vaccines and Injury particularly where underlying medical conditions and the temporal proximity of symptoms raise legitimate questions of medical causality in Covid-19 Vaccination Injury Cases.

COVID-19 Vaccination Injury Case in Korea

Factual Background

1. Decedent suffered from an undiagnosed underlying condition, later identified as Moyamoya disease.
2. On December 28, 2021, Decedent received a COVID-19 vaccination. Within two hours, he collapsed at home.
3. Decedent was transferred to a university hospital, diagnosed with an intracranial hemorrhage, and underwent a craniotomy. Despite treatment, his condition deteriorated, and he died seven days later.
4. The KDCA denied the spouse’s application for compensation, reasoning that the cause of death was intracranial hemorrhage due to Moyamoya disease and that a causal link with the vaccination was “difficult to acknowledge.”
5. The surviving spouse challenged the KDCA’s decision under the Administrative Litigation Act (행정소송법), seeking annulment of the denial.

Decision of Seoul Administrative Court

The Seoul Administrative Court ruled that” “It is difficult to conclude that the deceased’s death was caused solely by a cause other than vaccination. It does not appear impossible, under medical theory or empirical principles, to infer that the COVID-19 vaccination contributed to or aggravated the underlying Moyamoya disease, leading to the intracranial hemorrhage and eventual death. Accordingly, the KDCA’s contrary disposition is unlawful. . . There is no dispute between the parties that [Decedents] direct cause of death was intracranial hemorrhage, and that the preceding cause was Moyamoya disease, and that Moyamoya disease, a disease that occurs when the blood vessels in the area where the internal carotid artery, which supplies blood to the brain, branches gradually narrow without a specific cause, can cause cerebral hemorrhage.”

The Court continued that Decedent: “had never been diagnosed with a cerebrovascular disease, including Moyamoya disease, before being vaccinated, and it appears that he had never been treated for a cerebrovascular disease. . . [Decedent] collapsed two hours after being vaccinated, and while being treated at the hospital where he was transferred, we learned that he had developed Moyamoya disease. However, we do not know exactly when it developed or how far Moyamoya disease had progressed at the time of vaccination. In addition, no symptoms related to Moyamoya disease appeared before vaccination, so it is difficult to conclude that the deceased’s intracranial hemorrhage on the day of vaccination was completely unrelated to the vaccination in this case. . .There are cases where patients with Moyamoya disease suffered cerebral hemorrhage after receiving the COVID-19 vaccine, and there are studies that show that the incidence of cerebral hemorrhage in patients with Moyamoya disease tends to increase after vaccination based on analysis of these cases. Therefore, it is difficult to see it as impossible in medical theory or empirical principles to infer that the vaccination worsened underlying condition, Moyamoya disease, and led to his death.”

The Seoul Administrative Court’s judgment represents a landmark precedent in the recognition of vaccine-related injuries in Korea. For individuals seeking relief under the Infectious Disease Control and Prevention Act (감염병의 예방 및 관리에 관한 법률), this decision confirms that scientific uncertainty does not preclude compensation where temporal and empirical factors suggest a causal nexus.

Sean Hayes is the first non-Korean attorney to have worked for the Korean court system (Constitutional Court of Korea) and one of the first non-Koreans to be a regular member of a Korean law faculty. Sean is ranked, for Korea, as a Top Attorney by AsiaLaw, and IPG Legal is consistently ranked Top Dispute Resolution Law Firm for our litigation and arbitration services.

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