Noor Niwas Nursery Public School vs Regional Provident Fund Commr. & Ors

The Supreme Court held that under Section 2-A of the Employees Provident Funds and Miscellaneous Provisions Act, 1952, two units can be treated as a single establishment if they exhibit functional integrality. The Court found that the appellant-school and Francis Girls Higher Secondary School, despite claiming to be separate entities, were effectively one establishment due to their geographical proximity and shared management. The appeal against the Provident Fund Commissioner's decision was dismissed, affirming that both schools are covered under the Act.