In Brief
The Supreme Court upheld the coverage of two educational institutions under the Employees' Provident Funds Act, 1952. The Ideal Fine Arts Society operated both the Ideal Institute (8 employees, established 1965) and the College of Visual Arts (18 employees, established 1986) on the same campus. Although each institution individually employed fewer than 20 persons, clubbing them together totalled 26 employees, triggering EPF coverage. The Court held that common management, shared premises, and financial integrity between the institutions—demonstrated by loans from the parent Society and Trust—justified clubbing. The institution's arguments that they offered different courses, received different grant-in-aid levels, and had different approval sources were found irrelevant to EPF coverage determination. The appellant's burden to prove fewer than 20 employees for exclusion remained unmet.
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