BHARAT HEAVY ELECTRICALS LTD. vs ESI CORPORATION

The Supreme Court addressed the applicability of Section 45A of the Employees' State Insurance Act, 1948, in relation to the liability of a principal employer for contributions owed by contractors. The Court held that the principal employer is entitled to recover contributions from immediate employers under Sections 40 and 41 of the Act, and that the determination of contributions does not require the impleadment of contractors in proceedings. The judgment of the Madras High Court in Madras Gymkhana was overruled, affirming the interpretation of the ESI Act's provisions regarding employer liability.