N. MANOHARAN, ETC. versus THE ADMINISTRATIVE OFFICER AND ANOTHER

N. MANOHARAN, ETC. versus THE ADMINISTRATIVE OFFICER AND ANOTHER

HWP at Tuticorin is a project/establishment constituted and operating as an adjunct or ancillary of the Department of Atomic Energy (a Central Government department) and is not a separate corporate entity; therefore its employees fall within the exclusionary clause of s.2(e) of the Payment of Gratuity Act, 1972 (being persons holding posts under the Central Government or governed by rules providing gratuity), and consequently Sections 5 and 14 of the PG Act are not attracted; the appeals are dismissed.

Parties
Appellants: N. Manoharan and Others; Respondents: The Administrative Officer and Another
Jurisdiction
India
Judgment Date
11 February 2026
Procedural Posture
Civil Appeal / Appeal to Supreme Court (final Judgment)
Outcome
Civil Appeals dismissed.
Legal Topics
Applicability of Payment of Gratuity Act, 1972, Section 2(e) Exclusion Clause, Jurisdictional Fact, Status of Heavy Water Plant Vis À Vis Department of Atomic Energy, Interaction Between PG Act and CCS (pension) Rules
Labour and Employment Law Administrative Law Statutory Interpretation Applicability of Payment of Gratuity Act, 1972 Section 2(e) Exclusion Clause Jurisdictional Fact Status of Heavy Water Plant Vis À Vis Department of Atomic Energy Interaction Between PG Act and CCS (pension) Rules, 1972

Case Brief

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Parties

N. Manoharan and Others

Appellants

The Administrative Officer and Another

Respondents

Procedural Posture

Civil Appeal / Appeal to Supreme Court (final Judgment)

Legal Issues

  1. 1 Whether employees of Heavy Water Plant, Tuticorin are covered by Section 2(e) of the Payment of Gratuity Act, 1972
  2. 2 Whether Sections 5 and 14 of the Payment of Gratuity Act are attracted in this case
  3. 3 Whether HWP is an autonomous industrial establishment or an adjunct/ancillary of the Department of Atomic Energy (a Central Government department)

Ratio Decidendi

HWP at Tuticorin is a project/establishment constituted and operating as an adjunct or ancillary of the Department of Atomic Energy (a Central Government department) and is not a separate corporate entity; therefore its employees fall within the exclusionary clause of s.2(e) of the Payment of Gratuity Act, 1972 (being persons holding posts under the Central Government or governed by rules providing gratuity), and consequently Sections 5 and 14 of the PG Act are not attracted; the appeals are dismissed.

Court Disposition

Civil Appeals dismissed.

Orders

  • Civil Appeals dismissed.
  • Pending applications, if any, stand disposed of.