Birla Institute Of Technology vs The State Of Jharkhand

The Supreme Court held that under Section 2(e) of the Payment of Gratuity Act, 1972, a teacher does not qualify as an 'employee' and therefore is not entitled to claim gratuity from the employer. The Court found merit in the appellant's appeal, referencing the precedent set in Ahmadabad Pvt. Primary Teachers Association vs. Administrative Officer (2004) 1 SCC 755, which established that teachers are excluded from the definition of 'employee' under the Act. Consequently, the Court reversed the lower courts' decisions that had favored the respondent's claim for gratuity.