In Brief
The Supreme Court reversed the Guwahati High Court's decision excluding a cold storage factory from ESI Act coverage. The factory, located in Tarapur Village near Silchar, was not covered under a 1999 notification extending the Act to certain areas. The High Court held that only areas within Silchar Municipal limits were covered. The Supreme Court disagreed, ruling that the notification's explicit mention of multiple villages and areas—including Tarapur (named twice)—signified legislative intent to extend coverage beyond municipal boundaries. Using the principle that statutory words must not be treated as surplusage, the Court held the word "including" served as enlargement, making the factory's establishment covered by the ESI Act. The appeal was allowed.
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