STATE OF BIHAR vs S. K. ROY

The Supreme Court held that the respondent was not the owner of a coal mine as defined under Section 2(b) of the Mines Act, 1952, and therefore not an employer under Section 2(e) of the Coal Mines Provident Fund and Bonus Schemes Act, 1948. The Court clarified that the definition of 'coal mine' includes only those excavations where operations for obtaining coal are carried out, and the respondent's coke plant did not meet this criterion. The High Court's acquittal of the respondent was upheld, confirming that the legislative intent requires a strict interpretation of ownership in relation to coal mining operations.