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Supreme Court of India 2022-02-23 dismissed

Horticulture Experiment Station Gonikoppal, Coorg vs Regional Provident Fund Organization

Bench: 2 — Rastogi

In Brief

The Supreme Court upheld the right of the Provident Fund authorities to recover damages from employers for default in paying Employee Provident Fund (EPF) contributions. The case involved a horticultural station that failed to pay EPF contributions for over a decade, then was assessed dues and additionally charged damages. The employer argued that damages should require proof of fault or intention (mens rea). The Court held that for civil obligations like statutory contribution, no such intent element is necessary—default itself triggers the damages penalty. Once breach of the statutory obligation is established, damages follow automatically.

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Social Security Provident Fund Employer Obligations Damages and Penalties Civil Liability Mens Rea

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