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Issues Involved:
1. Jurisdiction of the Payment of Wages Authority under the Payment of Wages Act. 2. Definition of "wages" under the Payment of Wages Act. 3. Applicability of the Payment of Bonus Act to establishments managed by authorized controllers under the Industries (Development and Regulation) Act, 1951. 4. Exemption under Section 32(iv) of the Payment of Bonus Act. Detailed Analysis: 1. Jurisdiction of the Payment of Wages Authority under the Payment of Wages Act The primary question was whether the Payment of Wages Authority had jurisdiction to adjudicate claims for bonus under the Payment of Bonus Act. The court held that the Payment of Wages Authority is designed to handle simple, summary proceedings concerning deductions from wages or delays in payment. However, when complex legal issues arise, such as the interpretation of new legislation or statutory exemptions, the Payment of Wages Authority lacks jurisdiction. The court emphasized that the Payment of Wages Authority should not decide on complicated questions of law or fact, which are better suited for other forums like the Industrial Court, as stipulated under Section 22 of the Payment of Bonus Act. 2. Definition of "wages" under the Payment of Wages Act The court examined whether the bonus payable under the Payment of Bonus Act could be considered "wages" under the Payment of Wages Act. The definition of "wages" includes all remuneration payable under the terms of employment, whether by way of salary, allowances, or otherwise. The court held that the bonus payable under the Payment of Bonus Act qualifies as "wages" because it is remuneration that the employer is statutorily obligated to pay, thus forming part of the terms of employment. The court rejected the argument that "wages" should be limited to contractual remuneration, noting that the definition had been amended to include statutory payments. 3. Applicability of the Payment of Bonus Act to establishments managed by authorized controllers under the Industries (Development and Regulation) Act, 1951 The court considered whether the establishments managed by authorized controllers under the Industries (Development and Regulation) Act, 1951, were exempt from the Payment of Bonus Act. The court analyzed the provisions of the Industries (Development and Regulation) Act, particularly Sections 18-A, 18-B, and 18-E, which grant extensive control and management powers to the authorized controllers. The court concluded that these establishments are managed "under the authority of any department of the Central Government," thus falling within the exemption provided under Section 32(iv) of the Payment of Bonus Act. 4. Exemption under Section 32(iv) of the Payment of Bonus Act The crucial issue was whether the establishments in question were exempt under Section 32(iv) of the Payment of Bonus Act, which exempts "employees employed by an establishment engaged in any industry carried on by or under the authority of any department of the Central Government." The court held that the extensive control and management exercised by the authorized controllers, who act under the directions of the Central Government, bring these establishments within the scope of the exemption. The court emphasized that the authorized controllers are not mere agents but are vested with the full powers of the directors, effectively placing the establishments under the direct control of the Central Government. Conclusion: The court concluded that the Payment of Wages Authority lacked jurisdiction to adjudicate the claims for bonus under the Payment of Bonus Act due to the complexity of the legal issues involved. Furthermore, the court held that the establishments managed by authorized controllers under the Industries (Development and Regulation) Act, 1951, were exempt from the Payment of Bonus Act under Section 32(iv). Consequently, the orders of the Payment of Wages Authority were set aside, and the applications of the workmen were dismissed.
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