BIHAR STATE ELECTRICITY BOARD, PATNA. vs THEIR WORKMEN

The Supreme Court held that the Employees Provident Fund Act applies only to establishments classified as factories, impacting the applicability of benefits to employees in the electricity sector. The Court found that the Industrial Tribunal failed to adequately assess the financial implications of extending contributory provident fund benefits to all workmen, particularly regarding the appellant's financial capacity. The Tribunal's reliance on a previous award without proper financial analysis was deemed insufficient, leading to the appeal's allowance and a directive for a more thorough evaluation of the appellant's financial situation before imposing additional liabilities.