In Brief
The EPFO challenged a High Court order that had quashed action against an employer for non-payment of provident fund contributions under Section 14B of the EPF Act, 1952. The High Court found that the authorities had not established mens rea or actus reus (guilty mind or guilty act) on the employer's part, merely noting that financial crisis was no excuse. The Supreme Court dismissed the appeal, holding that mens rea/actus reus is determinative for damages under Section 14B, and absence of such findings by the original and appellate authorities cannot sustain the action, despite financial hardship being an invalid excuse for non-compliance."
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