Mcleod Russel India Limited vs Reg.Prov.Fund Comm.,Jalpaiguri & Ors

The Supreme Court examined the applicability of Section 14B of the Employees’ Provident Funds and Miscellaneous Provisions Act, 1952, in the context of defaults in remitting contributions by M/s. Mathura Tea Estate. The Court held that both the original employer, Saroda Tea Company Ltd., and the subsequent owner, Eveready Industries (India) Ltd., could be jointly and severally liable for damages due to non-payment of provident fund dues. The judgment reaffirmed the interpretation of liability under the EPF Act as established in Dalgaon Agro Industries Ltd. vs Union of India, thereby upholding the RPF Commissioner's decision regarding the imposition of damages.