Union of India v. Heavy Vehicles Factory Employees’ Union 2026 INSC 74 - Factories Act
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Factories Act, 1948: Section 59(2); Chapter VI (Sections 64, 65); Chapter XI (Sections 112, 113)- These sections do not empower the Central Government to issue any clarification or direction with reference to any provisions of the 1948 Act. None of the sections empowers the central government to even frame rules. The entire power is vested with the State Governments. All that the Central Government can do is, issue directions to the State Governments - when the statute provides for only two specific exclusions: bonus and wages for overtime work, in the absence of any formal rules governing the exclusion of other entitlements, the Executive cannot, through a mere Office Memorandum, read additional exclusions into the Act that the Legislature did not contemplate. (Para 15)
Interpretation of Statues - Legislature never wastes its words. (Para 15) Different Ministries of the Government of India cannot assign different meaning to a provision in the Act of Parliament. (Para 14.1)
Case Info
Case Details
- Case name: Union of India & Others v. Heavy Vehicles Factory Employees’ Union & Another
- Neutral citation: 2026 INSC 74
- Coram: Rajesh Bindal, J.; Manmohan, J.
- Judgment date: January 20, 2026
- Court: Supreme Court of India, Civil Appellate Jurisdiction; Civil Appeal Nos. 5185–5192 of 2016
Statutes/Laws Referred
- Factories Act, 1948: Section 59(2); Chapter VI (Sections 64, 65); Chapter XI (Sections 112, 113)
- General Clauses Act, 1897: Section 3(60) (definition of “State Government”)
- Payment of Wages Act, 1936: Section 2(vi)
- Industrial Disputes Act, 1947: Section 2(rr)
- Employees’ Provident Funds and Miscellaneous Provisions Act, 1952: Section 2(b)
Caselaws and Citations
- Bridge and Roof Co. Ltd. v. Union of India & Ors., 1962 SCC OnLine SC 164
- Govind Bapu Salvi & Ors. v. Vishwanath Janardhan Joshi & Ors., (1995) Supp (1) SCC 148
- Union of India & Ors. v. Suresh C. Baskey & Ors., 1995 INSC 721; (1996) 11 SCC 701
- Rajasthan State Industrial Development & Investment Corpn. v. Subhash Sindhi Coop. Housing Society, 2013 INSC 94; (2013) 5 SCC 427
- Gujarat Mazdoor Sabha & Anr. v. State of Gujarat, 2020 INSC 572; (2020) 10 SCC 459
- Y.A. Mamarde v. Authority under the Minimum Wages Act, (1972) 2 SCC 108 (quoted for overtime rationale)
- ITC Ltd. v. Provident Fund Commissioner, 1986 SCC OnLine P&H 715; ILR (1988) 1 P&H 73
- Hindustan Machine Tools Ltd. v. Labour Court, 1993 SCC OnLine Raj 17; (1994) 1 LLN 256
- V.E. Jossie & Ors. v. The Flag Officers Commanding in Chief Headquarters, 2011 SCC OnLine Ker 4030 (held not laying correct law)
