SANGHI JEEVARAJ GHEWAR CHAND & ORS. vs SECRETARY, MADRAS CHILLIES, GRAINS KIRANA MERCHANTS

The Supreme Court held that the Payment of Bonus Act, 1965, is exhaustive regarding bonus payments, and employees of establishments excluded under Section 1(3) and exempted under Section 32(x) cannot claim bonuses outside the Act. The Court emphasized that the Act was intended to comprehensively address the subject of bonuses, and historical legislative context supports this interpretation. Therefore, the claims for bonus by employees of the appellants were dismissed as they fell outside the statutory framework established by the Act.