SC: Beneficial provisions shouldn’t be expanded beyond their contours

On 15th March 2019, in the matter of Senior Divisional Manager, Life Insurance Corporation Of India & Ors. v. Shree Lal Meena, the Hon’ble Supreme Court observed that while interpreting beneficial provisions like Pension regulations, unincluded aspects cannot be included by implication. The provisions are to be read as they read unless there is some confusion or they are capable of another interpretation.

The Hon’ble Supreme Court observed that:

It is trite to say that statutory provisions must be given their clear meaning unless there is ambiguity in the wordings. (Para 18)

Any judgment has to be read for the law it lays down, by reference given to a factual matrix. (Para 20)

(Para 20) Lines or sentences here and there should not be read in absolute terms, de hors the factual matrix in the context of which those observations were made. [CIT v. Sun Engineering Works (P.) Ltd. (1992) 4 SCC 363]

Voluntary retirement is a concept read into a condition of service, which has to be created by a statutory provision, while resignation is the unilateral determination of an employer-employee relationship, whereby an employee cannot be a bonded labour. (Para 22)

When the Legislature, in its wisdom, brings forth certain beneficial provisions in the form of Pension Regulations from a particular date and on particular terms and conditions, aspects which are excluded cannot be included in it by implication. The provisions will have to be read as they read unless there is some confusion or they are capable of another interpretation. (Para 25)

While framing schemes like pension schemes, there is an important aspect of them being of a contributory nature and their financial implications. Such financial implications are both, for the contributors and for the State. Thus, it would be inadvisable to expand such beneficial schemes beyond their contours to extend them to employees for whom they were not meant for by the Legislature. (This inference has been drawn on the basis of Para 25)

Copy of judgement: Judgement_15-Mar-2019

-Tushar Kaushik

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