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Supreme Court of India 2022-02-23 dismissed

HORTICULTURE EXPERIMENT STATION GONIKOPPAL, COORG vs THE REGIONAL PROVIDENT FUND ORGANIZATION

Bench: 2 — Ajay Rastogi, Abhay S. Oka

In Brief

An agricultural establishment covered under the Employees Provident Fund Act failed to deposit EPF contributions from 1975 to 1988. After proceedings under Section 7A determined the arrears (₹74,288), the authority imposed damages of ₹85,548 under Section 14B. The employer argued that mens rea (guilty intention) was essential for imposing damages. The Supreme Court held that for civil obligations, mens rea is not required—breach of the statutory obligation itself is sufficient to attract damages. The Court relied on binding precedent establishing that civil penalties for statutory violations are imposed automatically upon proof of breach, irrespective of intent. The appeal was dismissed.

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Provident Fund Law Social Security Administrative Law Strict Liability Civil Penalties Labour Law

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