MUMBAI KAMGAR SABHA, BOMBAY vs M/S ABDULBHAI FAIZULLABHAI & ORS.

The Supreme Court held that the Payment of Bonus Act, 1965 is a complete code governing the entitlement to bonus, and customary payments made prior to the Act do not fall within its purview. The Court ruled that the workers' union, despite not being a formal party to the dispute, had locus standi to appeal on behalf of the workers. The appeal was dismissed as the Tribunal's decision was upheld, confirming that the claim for bonus based on custom was barred by res judicata due to prior arbitration findings.