THE GRAHAM TRADING CO. (INDIA) LTD. vs ITS WORKMEN

The Supreme Court ruled that while the workmen were not entitled to puja bonus as an implied term of employment due to the company's clear indication that past payments were ex gratia, they were entitled to it as a customary and traditional payment. The Court established that for a payment to be deemed customary, it must be made over an unbroken series of years, for a sufficiently long period, even in years of loss, and at a uniform rate. The judgment emphasized that unilateral declarations by the employer do not negate established customs.