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Legal Case Shots

Court judgements broken down into the case type, how the decision played out, and the lesson worth remembering, with the full judgement available as a PDF.

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Legal Case Shots is a searchable database of Supreme Court of India judgments, each broken down into the case type, the court's key holding, and a practical lesson learnt, with the full judgment available as a PDF for citation or deeper reading.

Labour & Industrial LawSupreme Court of India

Asst. Provident Fund Commissioner EPFO, Bareilly v. M/s U.P. State Warehousing Corp.

Civil Appeal · 2019 INSC 903Decided 14 Aug 2019
Civil Appeal No. 6295 of 2019
Justice Abhay Manohar Sapre · Justice R. Subhash Reddy

Background

This order sends the case back; it does not decide it. The EPF authorities demanded contributions from U.P. State Warehousing Corporation for 159 loading and unloading workers engaged through a contractor. The Allahabad High Court quashed the demand, relying on a finding under the Industrial Disputes Act that there was no master-servant relationship.

Decision Breakdown

This is not a final decision on liability. The Court held that the definition of employee in Section 2(f) of the EPF Act differs from that under the Industrial Disputes Act, so the High Court applied the wrong test. It sent the writ petition back to the High Court for a fresh decision.

Lesson Learnt

Whether workers are employees for provident fund purposes is decided under the EPF Act's own definition.

Asst. Provident Fund Commissioner EPFO, Bareilly v. M/s U.P. State Warehousing Corp. – Legal Case Shots | LegalAware