COAL MINES PROVIDENT FUND COMMISSIONER vs RAMESH CHANDER JHA

The Supreme Court held that the Coal Mines Provident Fund Commissioner qualifies as a 'public officer' under Section 2(17) of the Code of Civil Procedure, 1908. The Court clarified that the term 'service' encompasses more than mere subordination to government orders, emphasizing that the Commissioner, appointed by the government, performs functions under the Coal Mines Provident Fund Act. Consequently, the requirement of prior notice under Section 80 CPC is applicable, and the appeal was allowed, reversing the lower courts' decisions.