N. Manoharan, Etc vs The Administrative Officer and Anr

Bench: 2 — Pankaj Mithal, S.V.N. Bhatti

In Brief

Retired employees of Heavy Water Plant (HWP), a unit of the Department of Atomic Energy, sought additional gratuity under the Payment of Gratuity Act, 1972, claiming they were "employees" under that Act. The Supreme Court dismissed their appeals, upholding the High Court's decision. The Court held that since HWP employees are Central Government servants governed by Central Civil Services Pension Rules—which already provide gratuity—they fall within the statutory exclusion clause of Section 2(e) of the Gratuity Act. HWP is an ancillary unit of the Department, not a separate corporate entity, and employees cannot claim benefits under both schemes simultaneously.

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Labour Law Gratuity Government Employees Atomic Energy Statutory Interpretation Exclusionary Clauses Administrative Law Employee Benefits

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