Bombay Anand Bhavan Restaurant vs Dy. Director , Esi Corpn. And Anr

The Supreme Court upheld the applicability of the Employees' State Insurance Act, 1948 (ESI Act) to the appellant's establishment, ruling that the use of LPG gas for manufacturing beverages constitutes 'power' under Section 2(12) of the ESI Act. The Court clarified that the threshold of employing 10 or more employees is met when power is used in the manufacturing process, regardless of the type of power. Consequently, the Court affirmed the order of the ESI Court directing the appellant to pay contributions from April 1994, as the appellant was found to be covered under the ESI Act.