N.K. JAIN AND OTHERS vs C.K.SHAH AND OTHERS

The Supreme Court examined the applicability of the Employees’ Provident Funds and Miscellaneous Provisions Act, 1952, particularly Sections 6 and 14, in relation to an establishment exempted under Section 17. The Court held that failure to contribute to the provident fund as mandated by Section 6 constitutes a contravention attracting prosecution under Section 14, rather than merely leading to cancellation of exemption under Section 17(4). The judgment clarified that the nature of exemption does not equate to a penalty unless explicitly stated in the Act, thereby reinforcing the legislative intent behind the provisions.