HARIHAR POLYFIBRES vs THE REGIONAL DIRECTOR, ESI CORPORATION

The Supreme Court held that the term 'wages' as defined in Section 2(22) of the Employees' State Insurance Act, 1948, includes 'House Rent Allowance', 'Night Shift Allowance', 'Heat, Gas and Dust Allowance', and 'Incentive Allowance'. The Court emphasized that the definition is intentionally broad and should be interpreted liberally to fulfill the Act's social welfare objectives. The judgment overruled Bengal Potteries Ltd. v. Regional Director, W. Bengal Region, Employees State Insurance Corporation and others, [1973] LAB. I.C. 1328, which had a contrary interpretation.