VidhiSangh

Supreme Court of India · 25/04/2022

MANIBEN MAGANBHAI BHARIYA versus DISTRICT DEVELOPMENT OFFICER DAHOD & ORS.

[2022] 5 S.C.R. 760 · 2022 INSC 473

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Summary

Anganwadi workers and helpers challenged denial of gratuity on the grounds that their work was honorary and they were not statutory employees. In agreeing opinions, the Court held that the Payment of Gratuity Act applied: the centres were covered establishments, the workers performed substantial statutory duties, and the honorarium was wages. It restored the Single Judge’s decision and directed Gujarat authorities to extend benefits to eligible workers within three months, with 10% simple annual interest on overdue gratuity.

Issues

  1. Whether Anganwadi centres and their workers and helpers fell within the Payment of Gratuity Act.
  2. Whether honorary terminology or Ameerbi’s ruling on civil posts defeated gratuity entitlement.

Provisions considered

Held

Result

Appeals allowed. The Division Bench judgment was set aside and the Single Judge’s judgment restored. Gujarat authorities were directed to take necessary steps within three months to extend Gratuity Act benefits to eligible Anganwadi workers and helpers, with simple interest at 10% per annum from the date specified under Section 7(3A).

Judgment PDF: Supreme Court of India, [2022] 5 S.C.R. 760.