In Brief
The Supreme Court held that Gramin Dak Sewaks (rural postal agents) are Extra-Departmental Agents governed by the Gramin Dak Sewak Rules, 2011, which provides a separate gratuity regime. They do not qualify as 'employees' under the Payment of Gratuity Act, 1972 because Section 2(e) excludes persons governed by other gratuity-providing rules. Additionally, Rule 6(13) of the 2011 Rules bars gratuity payment when a Gramin Dak Sewak voluntarily resigns, except on medical grounds. The Court set aside the High Court's decision that had awarded gratuity to a respondent who resigned voluntarily.
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