B. Shah v. Presiding Officer, Labour Court, Coimbatore
Rule established
Maternity benefit must be calculated for all days of absence including Sundays and rest days, not just working days. Beneficial legislation must be construed liberally.
Facts
- Woman worker claimed maternity benefit under the Maternity Benefit Act, 1961
- Employer (B. Shah) paid benefit for working days only, excluding Sundays
- Calculated benefit as intermittent 6-day periods, not continuous calendar days
- Worker claimed benefit should cover all days she was absent, including Sundays
- Labour Court ruled in favour of the worker
- Employer appealed to Supreme Court
Issue
- Whether maternity benefit under Section 5(1) of the Maternity Benefit Act should be paid for all calendar days of absence (including Sundays) or only for actual working days.
Held
- Maternity benefit must be paid for all days of absence including Sundays and rest days
- The period of absence is a continuous period; Sundays falling within it cannot be excluded
- The Maternity Benefit Act is beneficial legislation enacted for women workers
- Must be construed liberally to advance its protective purpose
- Employer's narrow interpretation (working days only) defeated
Ratio Decidendi
Maternity benefit covers all days of the period of absence, including Sundays and holidays falling within that period. Being beneficial legislation, the Maternity Benefit Act must be interpreted liberally in favour of the beneficiary.
How to use it in an exam
- Authority for beneficial construction of the Maternity Benefit Act
- Use when asked about computation of maternity benefit period
- Also cited in IoS as an example of beneficial construction
- Key line: "The Supreme Court in B. Shah (1978) held that maternity benefit must cover all days of absence including Sundays, since the Act is beneficial legislation requiring liberal construction."
Source
Source: AIR 1978 SC 12
This is an educational summary, not the judgment itself. Cite the reported version in professional or academic work.