Rajasthan State Road Transport Corporation v. Its Workers
Rule established
ESI Act benefits are statutory entitlements that cannot be reduced by private agreements. Once the ESI Act applies to an establishment, the employer's liability to provide benefits under Section 46 is absolute and cannot be contracted out of.
Facts
- RSRTC employed workers covered under the ESI Act
- Corporation provided its own medical facilities and argued ESI coverage was duplicative
- Workers demanded ESI benefits in addition to or in place of employer's own scheme
Issue
- Whether an employer can avoid ESI Act obligations by providing alternative medical/welfare benefits.
Held
- ESI Act is a comprehensive social security statute; its application is mandatory
- Employer cannot contract out of or substitute alternative arrangements
- Benefits under Section 46 are statutory rights of insured employees
- Corporation bound to comply
Ratio Decidendi
The ESI Act is a self-contained social security code. Once it applies to an establishment, the rights and obligations it creates cannot be displaced by private agreements or employer-provided alternatives.
How to use it in an exam
- Authority on mandatory nature of ESI
- Part B on ESI Corporation and benefits
- Key line: "In Rajasthan SRT Corporation v. Its Workers (1964), the Supreme Court held that ESI Act obligations are mandatory and cannot be contracted out of, even if the employer provides alternative benefits."
Source
Source: AIR 1964 SC 1486
This is an educational summary, not the judgment itself. Cite the reported version in professional or academic work.