STATE OF PUNJAB vs LABOUR COURT, JULLUNDUR & ORS.

The Supreme Court held that the Payment of Gratuity Act, 1972, applies to industrial establishments, including those governed by the Payment of Wages Act, as per Section 1(3)(b). The Court clarified that retrenchment is not excluded from the definition of 'superannuation' under Section 4(1) of the Gratuity Act, thus entitling retrenched employees to gratuity. The appeal was allowed in part, affirming the Labour Court's decision to grant gratuity to the retrenched workers.