Court Directs State to Clarify Notification Status under Maternity Benefit Act, 1961
In a significant judgment, the Allahabad High Court has raised questions regarding the applicability of the Maternity Benefit Act, 1961 to educational institutions. The Division Bench comprising Justices Ajit Kumar and Swarupama Chaturvedi deliberated on the case Sunbeam Women's College v. Union of India and Others, emphasizing the necessity for a state notification to extend the Act's benefits to educational institutions.
The court examined the writ petition filed by Sunbeam Women's College challenging the order of the respondent commission, which directed reinstatement and benefits under the Maternity Benefit Act to an employee. The petitioner contended that the Act does not automatically apply to educational institutions unless notified by the State Government with the approval of the Central Government, as per the proviso to Section 2(1) of the Act. The court noted that no such notification had been issued to date.
Referencing a Kerala High Court judgment and a Supreme Court ruling, the court reiterated that educational institutions do not fall under the definition of "establishment" in the context of Shops and Establishments Acts. These institutions are engaged in organized activities to impart education rather than conducting business or trade. The court underscored the Supreme Court's position that educational institutions are not considered establishments under the Shops and Establishments Act.
The judgment directed the State Government of Uttar Pradesh to file an affidavit detailing actions taken to notify the Act for its implementation and extend benefits to workers in various establishments, including educational institutions. The court insisted on a status quo regarding the employment of the respondent in question, pending further orders.
This case highlights the complexities surrounding the application of labor laws to educational institutions, which are not traditionally classified as commercial establishments. The court's direction to involve the State Government underscores the need for clear legislative frameworks to ensure that employees in all sectors receive appropriate benefits.
The court has scheduled the matter for final disposal on March 23, 2026, and has mandated the filing of detailed counter affidavits by all respondents within four weeks. The judgment remains a pivotal point in the discourse on extending maternity benefits to employees in the education sector, pending the necessary governmental notifications.
Bottom Line:
Applicability of Maternity Benefit Act, 1961 to educational institutions requires notification by the State Government under proviso to Section 2(1) of the Act with the approval of the Central Government.
Statutory provision(s): Maternity Benefit Act, 1961 Section 2(1), Shops and Establishments Acts
Sunbeam Womans College v. Union of India, (Allahabad)(DB) : Law Finder Doc id # 2851309
