Bharat Heavy Electricals Ltd vs Esi Corporation

The Supreme Court addressed the applicability of Section 45A of the Employees' State Insurance Act, 1948, concerning the liability of a principal employer for contributions owed by contractors. The Court held that the principal employer cannot evade responsibility for ESI contributions by claiming that the contractors should be impleaded, as the Act allows recovery from the immediate employer under Sections 40 and 41. The judgment of the Madras High Court in Madras Gymkhana was overruled, affirming that the ESI Act does not require separate determinations for contributions owed by the principal and immediate employers.