ROHTAS INDUSTRIES LTD. vs RAMLAKHAN SINGH AND ORS.

The Supreme Court held that only a person classified as an employee under Section 2(4) of the Bihar Shops and Establishments Act, 1953, can file a complaint under Section 26(2). The Court clarified that individuals not considered 'workers' under the Factories Act, 1948, or those in managerial roles do not qualify as employees under the Bihar Act. The respondent was deemed a factory worker due to his connection with the manufacturing process, thus his complaint was ruled as not maintainable. The appeal was allowed, overturning the lower court's decision.