EMPLOYEES STATE INSURANCE CORPORATION vs DWARKA NATH BHARGWA

The Supreme Court held that Section 45B of the Employees State Insurance Act, 1948 allows for the recovery of unpaid contributions as arrears of land revenue, even if the contributions were due before the section's enactment on 28.1.1968. The Court clarified that since Section 45B is procedural, it can apply retrospectively to contributions that remained unpaid. The Court overturned the Allahabad High Court's decision, affirming that the Employees State Insurance Corporation could recover the dues as per Section 45B.