Authority: High Court at Calcutta
Order Date: 20 July 2026
Case Overview
- Petitioners: Asiatic Society’s Employees Union & Anr. (WPA 6229 of 2023)
- Respondents: Union of India, Ministry of Culture, Asiatic Society (as autonomous institution), EPF Authority, and others.
- Nature of proceeding: Constitutional writ jurisdiction (appellate side) challenging the restriction of employer’s EPF contribution to Rs 15,000 per month.
- Background:
- Service rules of the Society (effective 1 Dec 1998) under Clause 28 provided pension, gratuity, family pension and General Provident Fund benefits as for Central Government employees.
- Office memoranda (2 Dec 1997, 3 Sept 2008, 13 Jan 2017) directed PF deductions on the revised pay structure.
- Office order dated 18 May 2001 (Regulation VII) allowed employer and employee contributions at 12 % of salary, effective May 2001.
- Ministry of Culture communication dated 25 Jan 2023 limited EPF employer contribution to Rs 15,000 wage ceiling, directing immediate cessation of excess contributions.
- Respondent 2 (Asiatic Society) issued Office Order No. 6 Feb 2023 confirming the Rs 15,000 ceiling.
- CAG audit Report No. 4 of 2018 identified excess employer contribution of approx ₹7 crore (12 % of total pay instead of ceiling) made without Ministry approval.
- Multiple Ministry letters (04 May 2017, 13 Jun 2017, …, 25 Jan 2023, 8 Feb 2023) repeatedly instructed the Society to stop excess contributions and recover the excess.
- EPF Authority argued that breach of EPF provisions is a penal offence and may invoke inquiry under Sections 7A and 14B of the EPF & MP Act, 1952.
- Petitioners relied on Sections 26.6, 26A(2), 29(1), 31 and 12 of the Employees’ Provident Fund Scheme, asserting a joint request under 26.6 permits contributions above the ceiling.
- Respondent 1 (Union of India) contended that SR 28 of the Society’s service rules was not approved by the Government; therefore the Society acted ultra vires, violating the Government of India (Transaction of Business) Rules 1961 and Delegation of Financial Powers Rules 2024.
- Key statutory references cited:
- Section 26.6 (joint request for contribution above ceiling),
- Section 26A(2) (mandatory ceiling of Rs 15,000),
- Section 29(1) (contribution rates),
- Section 31 (employer’s share not to be deducted),
- Section 12 (prohibition on reducing wages due to PF liability).
Final Outcome
- The Court held that the Society’s employer contribution exceeding the statutory ceiling was unlawful and that SR 28 had not been approved, rendering the Society’s action ultra vires.
- The petition was found to be without merit and was dismissed.
- All interim orders, if any, were vacated.
- All applications connected with the writ were disposed of.
- The Court directed that a certified copy of the judgment be issued to the parties upon compliance with formalities.
Topics: EPF compliance, Government grant oversight, Judicial dismissal