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Supreme Court of India

EMPLOYEES PROVIDENT FUND COMMISSIONERversusO.L. OF ESSKAY PHARMACEUTICALS LIMITED

Citation
2011 INSC 787
Decided
8 November 2011
Disposal
Appeal(s) allowed

Holding

Section 11(2) of the EPF Act creates a first charge on the employer’s assets that must be paid in priority to all other debts, and this statutory priority is not displaced by the non‑obstante clause in Section 529A of the Companies Act.

Issues considered

  • Whether the priority granted to dues payable by an employer under Section 11(2) of the Employees' Provident Funds Act is subject to Section 529A of the Companies Act.
  • Whether the non‑obstante clause in the later Companies Act amendment overrides the earlier non‑obstante clause in the EPF Act.
  • How the terms ‘workmen’s dues’ and ‘first charge’ are to be interpreted in the context of winding‑up proceedings.

Legislation cited

Subjects

priority of duesnon obstante clauseEmployees' Provident Fund ActCompanies Actwinding upstatutory first chargeworkmen's duesinterpretation of statutessecured creditors

Judgment

                   (2011] 15 (ADDL.) S.C.R. 336


A       EMPLOYEES PROVIDENT FUND COMMISSIONER
                                  v.
         O.L. OF ESSKAY PHARMACEUTICALS LIMITED
                (Civil Appeal No. 9630 OF 2011)
                        NOVEMBER 8, 2011
B
              [G. S. SINGHVI AND H. L. DATTU, JJ.]

        Employees' Provident Funds and Miscellaneous
    Provisions Act, 1952:
c
        Object of its enactment - Discussed.

        s.11(2) - Priority of payment of contributions over other
   debts - Non-obstante clauses contained in s. 11 (2) of the EPF
  Act and s.529A of the Companies Act - Interpretation of the
D provisions - Held: By virtue of non-obstante clause contained
  in s. 11 (2) of the EPF Act, any amount due from an employer
  is deemed to be first charge on the assets of the
  establishment and is payable in priority to all other debts
  including the debts due to a bank, which falls in the category
E of the secured creditors - It cannot be said that the non-
  obstante clause contained in subsequent legislation i.e.
  s.529A(1) of the Companies Act prevails over the similar
  clause contained in s. 11 (2) of the EPF Act - While inserting
  s.529A in the Companies Act, Parliament, in its wisdom, did
F not declare the workmen's dues (which inC!udes various dues
  including provident fund) as first charge - The effect of the
  amendment is only to expand the scope of the dues of
  workmen and place them at par with the debts due to secured
  creditors and there is no reason to interpret this amendment
G as giving priority to the debts due to secured creditor over the
  dues of provident fund payable by an employer - Of course,
  after the amount due from an employer unde1 the EPF Act is
  paid, the other dues of the workers will be treated at par with
  the debts due to secured creditors and payment thereof will
H                               336
 EMPLOYEES PROVIDENT FUND COMMNR. v. O.L. OF 337
        ESSKAY PHARMACEUTICALS LTD.

be regulated by the provisions contained in s.529(1) read with   A
s.529(3), 529A and 530 of the Companies Act - Companies
Act, 1956 - s. 529A.

     Companies Act, 1956:

      ss.529, 530 (as amended) and s.529A - Interpretation of 8
- Held: By Companies (Amendment) Act, 1985, proviso was
q_dded to s.529(1) - By the same amendment, ss.529(3) and
529A were inserted - Simultaneously, the expression "subject
to the provisions of s.529A" was inserted in s.530(1) - The
object of the amendments was to ensure that the legitimate C
dues of workers should rank pari passu with those of secured
creditors - What Parliament has done by these amendments
is to define the term "workmen's dues" and to place them at
par with debts due to secured creditors to the extent such debts
rank under clause (c) of the proviso to s.529(1) - However, D
these amendments, though subsequent in point of time,
cannot be interpreted in a manner which would result in
diluting the mandate of s. 11 of the EPF Act - Interpretation
of statutes - Employees' Provident Funds and Miscellaneous
Provisions Act, 1952.                                            E
    s.529(1), proviso - Object of- Discussed.

    Interpretation of statutes:

     Contextual interpretation - Held: It is a well recognized F
rule of interpretatior. that every part of the statute must be
interpreted keeping in view the context in which it appears and
the purpose of legislation - Another rule of interpretation of
statutes is that if two special enactments contain provisions
which give overriding effect to the provisions contained G
therein, then the Court is required to consider the purpose and
the policy underlying the two Acts and the clear intendment
conveyed by the lang1,1age of the relevant provisions.

     Social welfare legislation - Interpretation of - Held: A
legislation made for the benefit of workers must receive a       H
    338    SUPREME COURT REPORTS [2011] 15 (ADDL.) S.C.R.


A liberal and purposive interpretation keeping in view the
    Directive Principles of State Policy contained in Articles 38
    and 43 of the Constitution - Constitution of India, 1950 -
    Employees' Provident Funds and Miscellaneous Provisions
    Act, 1952.
B
          Non-obstante clause - lnterpretarion of.

          Words and phrases:

         Expression 'workmen dues' - Meaning of, in the context
c   of s.529(3)(b) of the Companies Act, 1956.

      The question which arose for consideration in these
  appeals was whether priority given to the dues payable
  by an employer under Section 11 of the Employees'
D Provident Funds and Miscellaneous Provisions Act, 1952
  (EPF Act) is subject to Section 529A of the Companies
  Act, 1956 in terms of which the workmen's dues and
  debts due to secured creditors are required to be paid in
  priority to all other debts.

E         Allowing the appeals, the Court

       HELD: 1. An analysis of Section 11 of the Employees'
  Provident Funds and Miscellaneous Provisions Act, 1952
  shows that it gives statutory priority to the amount
F payable to the employees over other debts. Section 11(1)
  relates to an employer who is adjudged insolvent or
  being a company against whom an order of winding up
  is made. It lays down that the amount due from the
  employer in respect of any contribution payable to the
  Fund or, as the case may be, the Insurance Fund,
G damages recoverable under Section 148, accumulations
  required to be transferred under Section 15(2) or any
  charges payable by him under any other provision of the
  Act or the Scheme or the Insurance Scheme shall be paid
  in priority to all other debts in the distribution of the
H
 EMPLOYEES PROVIDENT FUND COMMNR. v. O.L. OF 339
        ESSKAY PHARMACEUTICALS LTD.
property of the insolvent or the assets of the company A
being wound up, as the case may be. Section 11 (2)
contains a non obstante clause and lays down that if any
amount is due from an employer whether in respect of
the employee's contribution deducted from the wages of
the employees or the employer's contribution, the same B
shall be deemed to. be the first charge on the assets of·
the establishment and shall, notwithstanding anything
contained in any other law for the time being in force, be
paid in priority to all other debts. To put it differently, sub-
section (2) of Section 1! not only declares that the c
amount due from an employer towards contribution
payable under the EPF Act shall be treated as the first
charge on the assets of the establishment, but also lays
down that notwithstanding anything contained in any
other law, such dues shall be paid in priority to all other
                                                                 0
debts. [Para 18] [354-G-H; 355-A-D]

    2. The Companies Act. Part VII of the Companies Act,
which consists of 5 Chapters contains provisions relating
to winding up of a company. The provisions contained
in Chapter V (Sections 528 to 560), which deal with proof E
and ranking of claims are applicable to every mode of
winding up. Section 528 lays down that in every winding
up, all debts payable on a contingency, and all claims
against the company, present or future, certain or
contingent, ascertained or sounding only in damages, F
shall be admissible to proof against the company. This
is subject to the rider that in the case of insolvent
companies, law of insolvency will be applicable in
accordance with the provisions of the Companies Act.
Section 529 deals with application of insolvency rules in G
winding up of insolvent companies. Section 530, as it
existed prior to the amendment of the Companies Act by
Act No.35 of 1985, gave priority to revenue of the State
and local authorities and various amounts payable to
                                                                H
    340    SUPREME COURT REPORTS [2011] 15 (ADDL.) S.C.R


A   employees including the dues payable from a provident
    fund, a pension fund, a gratuity fund or any other fund
    maintained by the company for the welfare of the
    employees. By the Companies (Amendment) Act No.35
    of 1985, proviso was added to Section 529(1). By the
s   same amendment, Sections 529(3) and 529A were
    inserted in the Companies Act. Simultaneously, the
    expression "subject to the provisions of Section 529A"
    was inserted in Section 530(1). By inserting proviso in
    Section 529(1 ), Parliament ensured protection of the
c   interest of the workmen in winding up proceedings. The
    object of this amendment is to place the legitimate dues
    of workers at par with those of secured creditors. This
    is also a legislative recognition of the fact that the
    workmen contribute to the growth of the capital and
D   industry and in the event of winding up of the company,
    they are entitled to get their legitimate share in the assets
    of the company by being treated at par with other
    secured creditors. With the insertion of Section 529(3)(a),
    the definition of the term ·workmen' contained in the
    Industrial Disputes Act, 1947 has been incorporated in the
E   Companies Act for the purposes of Sections 529, 529A
    and 530. The expression "workmen's dues" has been
    defined in Section 529(3)(b) to mean all wages or salary
    including wages payable for time or piece work and
    salary earned wholly or in part by way of commission of
F   any workman in respect of services rendered to the
    company and any compensation payable to any
    workman under the Industrial Disputes Act, 1947, all
    accrued holiday remuneration payable to any workman,
    or in the case of his death to any other person in his right
G   upon the termination of his employment before the
    passing of winding up order and all sums due to any
    workman from a provident fund, a pension fund, a
    gratuity fund or any other fund for the welfare of the
    workmen, which is maintained by the company. The
H
EMPLOYEES PROVIDENT FUND COMMNR. It O.L. OF 341
       ESSKAY PHARMACEUTICALS LTD.
definition also takes within its fold funds capable of being A
transferred to and vested in the workman under a
contract with insurers under Section 14 of the Workmen's
Compensation Act as also the amounts due in respect of
any compensation or liability for compensation under the
Workmen's Compensation Act in respect of the death or B
disablement of any workman of the company. By virtue
of the non obstante clause contained in sub-section (1)
of Section 529A, statutory priority has been given to the
workmen's dues and debts due to secured creditors over
all other dues. [Paras 19, 21) [355-E-H; 356-A-B; 360-C- c
H; 361-A]

    Organo Chemical Industries v. Union of India (1979) 4
SCC 573: 1974 (3) SCR 813; Central Bank of India v. State
of Kera/a (2009) 4 SCC 94: 2009 (3) SCR 735; Builders
Supply Corporation v. Union of India (1965) 2 SCR 289; State D
Bank of Bikaner and Jaipur v. National lrori and Steel Rolling
Corporation (1995) 2 SCC 19: 1994 (6) Suppl. SCR 566;
Dena Bank v. Bhikhabhai Prabhudas Parekh & Co. (2000) 5
SCC 694: 2000 (3) SCR 50; State of M.P. v. State Bank of
Indore (2002) 10 SCC 441 - relied on.                          E

     3. The EPF Act is a social welfare legislation intended
to protect the interest of a weaker sec~ion of the society,
i.e. the workers employed in factories and other
establishments, who have made significant contribution F
in economic growth of the country. The workers and
o~her employees provide services of different kinds and
ensure continuous production of goods, which are made
available to the society at large. Therefore, a legislation
made for their benefit must receive a liberal and G
purposive interpretation keeping in view the Directive
Principles of State Policy contained in Articles 38 and 43
of the Constitution. [Para 22) (361-8-E]

   4. The object of the amendments made in the
Companies Act by. Act No. 35 of 1985 was to ensure that H
    342   SUPREME COURT REPORTS [2011] 15 (ADDL.) S.C.R


A   the legitimate dues of workers should rank pari passu
    with those of secured creditors. In other words, these
    amendments are intended to protect the interest of the
    workmen in winding up proceedings by placing them at
    par with secured creditors and a statutory charge is
B   created qua their dues on all available securities forming
    part of the assets of the company in liquidation. There is
    nothing in the language of Section 529A which may give
    an indication that legislature wanted to create first charge
    in respect of the workmen's dues, as defined in Sections
c   529(3)(b) and 529A and debts due to the secured
    creditors. [Paras 35-36] [379-G-H; 380-A-F]

       5. It is a well recognized rule of interpretation that
  every part of the statute must be interpreted keeping in
  view the context in which it appears and the purpose of
D legislation. Another rule of interpretation of Statutes is that
  if two special ehactments contain provisions which give
  overriding effect to the provisions contained therein, then
  the Court is required to consider the purpose and the
  policy underlying the two Acts and the clear intendment
E conveyed by the language of the relevant provisions.
  [Paras 37-38] [380-G-H; 381-A-F]

        RBI v. Peerless General Finance and Investment Co. Ltd.
    (1987) 1 SCC 424: 1987 (2) SCR 1; Shri Ram Narain v.
F   Sim/a Banking and Industrial Co. Ltd. 1956 SCR 603;
    Kumaon Motor Owners' Union Ltd. v. State of Uttar Pradesh
    (1966) 2 SCR 121; Ashok Marketing Limited v. Punjab
    National Bank (1990) 4 SCC 406: 1990 (3) SCR 649 - relied
    on.

G     6. Even before the insertion of proviso to Sections
  529(1 ), 529(3) and Section 529A and amendment of
  Section 530(1), all sums due to any employee from a
  provident fund, a pension fund, a gratuity fund or any
  other fund established for welfare of the employees were
H payable in priority to all other debts in a winding up
 EMPLOYEES PROVIDENT FUND COMMNR. v. O.L. OF 343
        ESSKAY PHARMACEUTICALS LTD.

proceedings [Section 530(1)(f)]. Even the wages, salary       A
and other dues payable to the workers and employees
were payable in priority to all other debts. What
Parliament has done by these amendments is to define
the term "workmen's dues" and to place them at par with
debts due to secured creditors to the extent such debts       B
rank under clause (c) of the proviso to Section 529(1 ).
However, these amendments, though subsequent in
point of time, cannot be interpreted in a manner which
would result in diluting the mandate of Section 11 of the
EPF Act, sub-section (2) whereof declares that the            c
amount due from an employer shall be the first charge
on the assets of the establishment and shall be paid in
priority to all other debts. The words "all other debts"
used in Section 11 (2) would necessarily include the
debts due to secured creditors like banks, financial
                                                              0
institutions etc. The mere ranking of the dues of workers
at par with debts due to secured creditors cannot lead
to an inferl:!nce that Parliament intended to create first
charge in favour of the secured creditors and give priority
to the debts due to secured creditors over the amount
due from the employer under the EPF Act. Therefore, in        E
terms of Section 530(1), all revenues, taxes, cesses and
rates due from the company to the Central or State
Government or to a local authority, all wages or salary or
any employee, in respect of the services rendered to the
company and due for a period not exceeding 4 months           F
all accrued holiday remuneration etc. and all sums due
to any employee from provident fund, a pension fund, a
gratuity fund or any other fund for the welfare of the
employees maintained by the company are payable in
priority to all other debts. This provision existed when      G
Section 11 (2) was inserted in the EPF Act by Act No. 40
of 1973 and any amount due from an employer in respect
of the employees' contribution was declared first charge
on the assets of the establishment and became payable
in priority to all other debts. However, while inserting      H
    344   SUPREME COURT REPORTS [2011] 15 (ADDL.) S.C.R.


A  Section 529A in the Companies Act by Act No.35 of 1985
   Parliament, in its wisdom, did not declare the workmen's
   dues (this expression includes various dues including
   provident fund) as first charge. The effect of the
   amendment made in the Companies Act in 1985 is only
B to expand the scope of the dues of workmen and place
   them at par with the debts due to secured creditors and
   there is no reason to interpret this amendment as giving
   priority to the debts due to secured creditor over the dues
   of provident fund payable by an employer. Of course,
C after the amount due from an employer under the EPF Act
   is paid, the other dues of the workers will be treated at
   par with the debts due to secured creditors and payment
   thereof will be regulated by the provisions contained in
   Section 529(1) read with Section 529(3), 529A and 530 of
   the Companies Act. [paras 42, 43] [383-C-H; 384-A-E]
0
        Maharashtra State Cooperative Bank Ltd. v. Assistant
   Provident Fund Commissioner (2009) 10 SCC 123: 2009 (15)
   SCR 1; Maharashtra Tubes Ltd. v. State Industrial and
   Investment Corporation of Maharashtra Ltd. (1993) ·2 SCC
E 144: 1993 (1) SCR 340; Recovery Officer and Asstt.
   Provident Fund Commissioner v. Kera/a Financial
   Corporation ILR (2002) 3 Kerala; Allahabad Bank v. Canara
  Bank (2000) 4 sec 406: 2000 (2) SCR 1102 UCO Bank v.
  Official Liquidator, High Court of Bombay (1994) 5 SCC 1:
F 1994 (1) Suppl. SCR 294; A.P. State Financial Corporation
  v. Official Liquidator (2000) 7 SCC 291: 2000 (2) Suppl. SCR
  288 Textile Labour Association v. Official Liquidator (2004) 9
  sec 741: 2004 (3) SCR 1161; /CIC/ Bank Ltd. v. S/DCO
  Leathers Ltd. (2006) 10 sec 452: 2006 (1) Suppl. SCR 528;
G Rajasthan State Financial Corporation v. Official Liquidator
  (2005) 8 sec 190: 2005 (3) Suppl. SCR 1073; UCO Bank
  v. Official Liquidator, High Court, Bombay (1994) 5 SCC 1:
  1994 (1) Suppl. SCR 294- referred. to.

H
EMPLOYEES PROVIDENT FUND COMMNR. v. O.L. OF 345
       ESSKAY PHARMACEUTICALS LTD.

                   Case Law Reference:                     A

 2009 (15) SCR 1            referretl to   Para 11
 1993 (1) SCR 340           referred to    Para 12

 1974 (3) SCR 813 .         relied on      Para 22         B
 ILR (2002) 3 Kerala 4      referred to    Paras 23, 28
 2009 (3) SCR 735           relied on      Para 24

 (1965) 2 SCR 289           relied on      Para 25
                                                           c
 1994 (6) Suppl. SCR 566    relied on      Paras 26, 27,
                                           28
 2000 (3) SCR 50            relied on      Paras 26, 27,
                                           28
                                                           D
 (2002) 10 sec 441          relied on.     Paras 26, 27,
                                           28

 2000 (2) SCR 1102          referred to    Paras 28, 32,
                                           33,34
                                                           E
 1994 (1) Suppl. SCR 294    referred to    Paras 29, 31

 2000 (2) Suppl. SCR 288    referred to    Paras 29 31,
                                           34

 2004 (3) SCR 1161          referred to    Paras 29, 31    F
 2006 (1) Suppl. SCR 528    referred to    Paras 29, 33

 2005 (3) Suppl. SCR 1073 referred to      Para 33
 1994 (1) Suppl. SCR 294    referred to    Paras 29, 31
                                                           G
 1987 (2) SCR 1             relied on      Para 37

 1956 SCR 603               relied on      Para 39

 (1966) 2 SCR 121           relied on      Para 40
                                                           H
    346 SUPREME COURT REPORTS [2011] 15 (ADDL.) S.C.R.

A      1990 (3) SCR 649                relied on      Para 41

        CIVIL APPELLATE JURISDICTION : Civil Appeal No.
    9630 of 2011.
       From the Judgment & Order dated 18.9.2008 of the High
B Court of Gujarat in O.J. Appeal No. 269 of 20Q7 in Company
  Application No. 370 of 2007.

                                  WITH

         C.A. Nos. 9632, 9631 & 9633 of 2011.
c
         Aparna Bhat, P. Ramesh Kumar for the Appellant.

         Gaurav Agrawal for the Respondent.

         The Judgment of the Court was delivered by
D
         G.S. SINGHVI, J. 1. Delay condoned.
         2. Leave granted.

E       3. The question which arises for consideration in these
  appeals is whether priority given to the dues payable by an
  employer under Section 11 of the Employees' Provident Funds
  and Miscellaneous Provisions Act, 1952 (for short, 'the EPF
  Act') is subject to SectjOn 529A of the Companies Act, 1956
  (for short, 'the Companies Act') in terms of which the workmen's
F dues and debts due to secured creditors are required to be
  paid in priority to all other debts.

       4. For the sake of convenience, we have culled out the
  facts from the record of the appeal arising out of SLP(C) No.
G 7642/2011.

         5. Messrs Esskay Pharmaceuticals Limited is a company
    registered under the Companies Act. It falls within the definition
    of 'employer' under Section :2(e) of the EPF Act. On account
H
EMPLOYEES PROVIDENT FUND COMMNR. v. O.L. OF 347
 ESSKAY PHARMACEUTICALS LTD. [G.S. SINGHVI, J.)

of the company's failure to pay the dues under the EPF Act for A
the periods from March 1998 to May 1999 and June 1999 to
August 2001, the competent authority passed two orders under
Section 7A of the EPF Act and held that it'was liable to pay
Rs.14,96,751/-. The company appears to have paid a sum of
Rs.4,02,126/- but did notpay the remaining amount despite the B
issue of demand notices dated 12.4.2001 and 19.4.2001 by
the competent authority. The orders passed under Section BF
of the EPF Act, which were communicated to the bankers of
the company also did not yield the desired result. The
competent authority then issued warrant for attachment of the c
company's property. This was followed by sale notice dated
20.9.2001.

     6. Although, it is not clear from the record as to what
happened to the sale notice, but this much is evident that after
2 years and about 4 months, the Enforcement Officer informed D
the appellant that the Gujarat High Court has passed order
dated 11.3.2004 for winding up of the company and appointed
Official Liquidator to look after its properties and clear the
debts. The appellant then approached the Official Liquidator for
payment of the amount determined under Section 7A of the E
EPF Act, but the latter did not give any response.

     7. Company Application No. 356/2007 filed by the
appellant for issue of a direction to the Official Liquidator to pay
the amount payable by the employer under the EPF Act was F
dismissed by the learned Company Judge by relying upon the
order passed by the Division Bench of the High Court in
Company Application No. 216 of 1997 in Company Petition
No.205 of 1996 and order dated 31.8.2005 passed in
Company Application No.195 of 2005 - Regional Provident G
Commis3ioner-I v. M.A. Kuvadia, O.L. and others.

     8. The appellant challenged the order of the learned
Company Judge· by filing an appeal but could not convince the.
Division Bench of the High Court to entertain his plea that the
amount due from the employer is first charge on the assets of H
    348      SUPREME COURT REPORTS [2011] 15 (ADDL.) S.C.R.


A   the company and is payable in priority to all other dues. The
    Division Bench relied upon the judgment of the co-ordinate
    Bench and held that the learned Company Judge did not
    commit any error by dismissing the application filed by the
    appellant.    ·
B
       9. Since the impugned judgment and the order passed by
  the learned· Company Judge are entirely based on the order
  passed by another Division Bench in Company Application No.
  216/1997 in Company Petition No. 205/1996, it will be
  appropriate to notice the ratio of that order. The same is as
C under:                      ·

           "Section-530, Sub-section (1 ), clearly observes that in a
          winding up matter, subject to the provisions of Section-
          529(A), there shall be paid in priority to all other debts,
D         dues of the Government, which are in the form of revenues,
          tax, etc. When Section-530 is made subordinate to
          Section-529(A), then, a Court is obliged to look into the
          material provisions as contained under Seclion-529(A).
          Section-529(A) clearly provides chat notwithstanding
E         anything contained in any other provisicm of the Companies
          Act or any other law for the time being in force, in the
          winding up of a company, workmen's dues and debts due
          to the secured creditors to the extent such debts ;ank under
          clause (c) of the proviso to sub-section (1) of Section-529
F         pari passu with such dues, shall be paid in priority to all
          other debts.

           Section-529(A) has been introduced in the year 1985. It
          starts with a non-obstante clause. It clearly provides that
          "notwithstanding anything contained in any other provision
G         of the Act or any other law for the •ime being in force". A
          true understanding of Section-529(A) would make clear
          that the provisions of Section-529(A) shall override the
          provisions contained in Seclion-530. Not only this, the
          provisions contained in Section-529(A) shall override th~
H         provisions contained in the ESI Act because the ESI Ac.;!
EMPLOYEES PROVIDENT FUND COMMNR. v. O.L. OF 349
 ESSKAY PHARMACEUTICALS LTD. [G.S. SINGHVI, J.]

    is an Act of 1948, while the amendment in the Companies            A.
    Act has been made in the year 1985 and with the fullest
    knowledge that it was to override the provisions contained
    in Section-530. If Section-94 of the ESI Act and Section-
    530 of the Companies Act are made subordinate to
    Section-529(A), then, Section-529(A) shall march over the          B
    rights of others to which the others are entitled either under
    the special laws or under Section-530 of the Companies
    Act. A combined/conjoint reading of Section-529(A) of the
    Companies Act would make clear that in a matter of
    winding up, the workmen's dues and the debts due to the            c
    secured creditors to the extent such debts rank under
     clause (c) of the proviso to Sub-section (I) of Section-
    529(A) pari passu with such dues, shall be paid in priority
    to all other debts. If such dues and debts are paid in full
    and even thereafter, some money is left with the Official          D
     Liquidator f~r its distribution, then, such money can .be
    distributed under Section-530 of the Companies Act.
    When such a situation crops up, the State Government or
     the Central Government of the Local Authority may file their
     claim before the learned Company Judge and at that point          E
     of time, they may say that in view of their preferential right,
     either under the Local Act or under Section-530 of the
     Companies Act, they be paid."

     10. The factual matrix of the other appeals is more or less
similar. In all the cases, applications filed by the appellant for F
payment of the amount due from the employer were dismissed
by the learned Company Judge and the appeals were
dismissed by the Division Bench of the High Court . .
     11. Ms. Aparna Bhat, learned counsel for the appellant G
relied upon the judgment in Maharashtra State Cooperative
Bank Ltd. v. Assistant Provident Fund Commissioner (2009)
10 sec 123 and argued that the impugned judgment. and the
order of the learned Company Judge are liable to be set aside
because the High Court's interpretation of Section 11 of the H
    350     SUPREME COURT REPORTS [2011] 15 (ADDL.) S.C.R.


A   EPF Act is contrary to the law laid down by this Court. She
    submitted that even though Section 529A of the Companies Act
    also contains a non obstante clause, the provisions contained
    therein cannot override Section 11 (2) of the EPF Act in terms
    of which the amount due from an employer in respect of the
s   employees contribution is treated as first charge on the assets
    of the company and is payable in priority to all other debts. Ms.
    Bhat further argued that the EPF Act is a special legislation for
    institution of various types of funds and the schemes and in view
    of the non obstante clause contained in Section 11 (2), priority
c   given to the dues payable by an employer will prevail over the
    priority given under Section 529A of the Companies Act to the·
    workmen's dues and debts due to secured creditors.

        12. Shri Gaurav Agrawal, learned counsel for respondent
  No.1 supported the impugned judgment and argued that the
D statutory priority given to the dues of the employees under
  Section 11 (2) of the EPF Act cannot override the priority ·given
  to the dues of workers and secured creditors under Section
  529A(1) of the Companies Act because Parliament had
  inserted that section in the Companies Act with effect from
E 24.5.1995 knowing fully well priority given to the dues of the
  employees under the EPF Act. He further argued that the non
  obstante clause contained in the subsequent legislation, i.e.
  Section 529A (1) of the Companies Act would prevail over
  similar clause contained in the earlier legis'ation, i.e. Section
F 11 (2) of the EPF Act. In support of this argument, Shri Agrawal
  relied upon the judgment of this Court in Maharashtra Tubes
  Ltd. v. ,State Industrial and Investment Corporation of
  Maharashtra Ltd. (1993) 2 SCC 144.

G        13. We have considered the respective arguments. For
    deciding the question arising in these appeals, it will be useful
    to notice the relevant statutory provisions.

    The EPF Act

H         14. Section 11 (unamended) of the EPF Act was as under:
EMPLOYEES PROVIDENT FUND COMMNR. v. O.L. OF 351
 ESSKAY PHARMACEUTICALS LTD. [G.S. SINGHVI, J.]

    "11. Priority of payment of contributions over other A
    debts.- Where any employer is adjudicated insolvent or,
    being a company, an order for winding up is made, the
    amount due-

    (<!) from the employer in relation to an establishment to
                                                                 8
    which any Scheme applies in respect of any contribution
    payable to the Fund, damages recoverable under Section
    14-8, accumulations required to be transferred under sub-
    section (2) of Section 15 or any charges payable by him
    under any other provision of this Act or of any provision of C
    the Scheme; or

    (b) from the employer in relation to an exempted
    establishment in respect of any contribution to the
    provident fund (in so far as it relates to exempted
    employees), under the rules of the provident fund (any D
    contribution payable by him towards the Family Pension
    Fund under sub-section (6) of Section 17), damages
    recoverable under Section 13-8 or any charges payable
    by him to the appropriate Government under any provision
    of this Act or under any of the conditions specified under E
    section 17,

    shall where the liability therefor has accrued before the
    order of adjudication or winding up is made, be deemed
    to be included, among the debts which under Section 49
    of the Presidency-towns Insolvency Act, 1909, or under F
    Section 61 of the Provincial Insolvency Act, 1920 or under
    Section 230 of the Indian Companies Act, 1913, are to be
    paid in priority to all other debts in the distribution of the
    property of the insolvent or the assets of the company
    being wound up, as the case may be."                           G

    15. The EPF Act was amended by Act Nos. 40 of 1973,
19 of 1976 and 33 of 1988. By Act No. 40 of 1973, Section
11 was renumbered as Section 11 (1) and a new sub-section
was added as Section 11 (2) and it was declared that any          H
    352     SUPREME COURT REPORTS (2011] 15 (ADDL.) S.C.R.


A   amount due from an employer in respect of the employees'
    contribution shall be deemed to be the first charge on the assets
    of the establishment and shall be paid in priority to all other
    debts. The scope pf Section 11 (2) was enlarged by Act No.
    33 of 1988 by including the employer's contribution.
B
         16. The background in which Amendment Act No.33 of
    1988 was passed is discernible from the Statement of Objects
    and Reasons appended to the Employees' Provident Funds
    and Miscellaneous Provisions (Amendment) Bill, 1988, the
    relevant portions of which are extracted below:
c
          "The Employees' Provident Funds and Miscellaneous
          Provisions Act, 1952 provides for the institution of
          Compulsory Provident Fund; Family Pension Fund and
          Deposit Linked Insurance Fund, for the benefit of the
D         employees in factories and other establishments. The Act
          is at present applicable to 1-73 industries and classes of
          establishments employing twenty or more persons. As on
          31-3-1987, about 1.66 1akh establishments with about
          1.38 crore subscribers were covered under the Act.
E
          2. The Act was last amended in 1976. The Government
          had set up a high level Committee in April, 1980 to review
          the working of the Employees' Provident Funds
          Organisation and to suggest improvements. The
          Committee had made a number of recommendations
F         involving amendment of the Act. The Central Board of
          Trustees, Employees' Provident Fund had also, from time
          to time, made certain recommendations for amendment
          of the Act. The Standing Labour Committee had at its
          meeting held in September, 1986 considered inter alia the
G         question of enhancement of the rate of provident fund
          contribution and recommended suitable enhancement.

          3. Based on the above recommendations, it is proposed
          to carry on certain amendments in the Act. Some of the
H         more important amendments are:-
EMPLOYEES PROVIDENT FUND COMMNR. v. O.L. OF 353
 ESSKAY PHARMACEUTICALS LTD. [G.S. SINGHVI, J.]

    (i) to (v) xxxx xxxx xxxx                                       A

    (vi) a provision is being made for treating the entire amount
    of arrears of provident fund dues as first charge on the
    assets of an establishment in the event of its liquidation;

    xxxx xxxx xxxx"                                                 8

    17. Section 11, as it stands after the amendment of 1988,
reads as under:

    "11. Priority of payment of contributions over other C
    debts.- (1) Where any employer is adjudicated insolvent
    or, being a company, an order for winding up is made, the
    amount due -

     (a)   from the employer in relation to an establishment to
           which any Scheme or the Insurance Scheme applies D
           In respect of any contribution payable to the Fund
           or, as the case may be, the Insurance Fund
           damages recoverable under section 148,
           accumulations required to be transferred under sub-
           section (2) of section 15 or any charges payable by E
           him under any other provision of this Act or of any
           provision of the Scheme or the Insurance Scheme;
           or

     (b)    from the employer in relation to an exempted F
            establishment in respect of any contribution to the
            provident fund or any insurance fund (in so far it
            relates to exempted employees), under the rules of
            the provident fund or any insurance fund, any
            contribution payable by him towards the Pension G
            Fund under sub-section (6) of section 17, damages
            recoverable under section 148 or any charges
            payable -by him to the appropriate Government
            under any provision of this Act, or under any of the
            conditions specified under section 17,
                                                                 H
    354     SUPREME COURT REPORTS [2011] 15 (ADDL.) S.C.R.


A         shall, where the liability therefore has accrued before the
          order of adjudication or winding up is made, be deemed
          to be included among the debts which under section 49
          of the Presidency Towns Insolvency Act, 1909 (3of1909),
          or under section 61 of the Provincial Insolvency Act, 1920
B         (5 of 1920), or under section 530 of the Companies Act,
          1956 (1 of 1956), are to be paid in priority to all other
          debts in the distribution of the property of the insolvent or
          the assets of the company being wound up, as the case
          may be.
c         Explanation. - In this sub-section and in section 17,
          "insurance fund" means any fund established by an
          employer under any scheme for providing benefits in the
          nature of life insurance to employees, whether linked to
          their deposits in provident fund or not, without payment by
D         the employees of any separate contribution or premium in
          that behalf.

          (2) Without prejudice to the provisions of sub-section (1),
          if any amount is due from an employer whether in respect
          of the employee's contribution (deducted from the wages
E
          of the employee) or the employer's contribution, the amount
          so due shall be deemed to be the first charge on the
          assets of the establishment, and shall, notwithstanding
          anything contained in any other law for the time being in
          force, be paid in priority to all other debts."
F
       18. An analysis of Section 11 of the EPF Act shows that
  it gives statutory priority to the amount payable to the
  employees over other debts. Section 11 (1) relates to an
  employer who is adjudged insolvent or being a company
G against whom an order of winding up is made. It lays down that
  the amount due from the employer in respect of any contribution
  payable to the Fund or, as the case may be, the Insurance
  Fund, damages recoverable under Section 148, accumulations
  required to be transferred under Section 15(2) or any charges
H payable by him under any other provision of the Act or the
EMPLOYEES PROVIDENT FUND COMMNR. v. O.L. OF 355
 ESSKAY PHARMACEUTICALS LTD. [G.S. SINGHVI, J.]
Scheme or the Insurance Scheme shall be paid in priority to all A
other debts in the distribution of the property of the insolvent or
the assets of the company being wound up, as the case may
be. Section 11 (2) contains a non obstante clause and lays down
that if any amount is due from an employer whether in respect
of the employee's contribution deducted from the wages of the B
employees or the employer's contribution, the same shall be
deemed to be the first charge on the assets of the
establishment and shall, notwithstanding anything contained in
any other law for the time being in force, be paid in priority to
all other debts. To put it differently, sub-section (2) of Section c
11 not only declares that the amount due from an employer
towards contribution payable under the EPF Act shall be treated
as the first charge on the assets of the establishment, but also
lays down that notwithstanding anything contained in any other
law, such dues shall be paid in priority to all other debts.
                                                                    D
The Companies Act

      19. Part VII of the Companies Act, which consists of 5
Chapters contains provisions relating to winding up of a
company. The provisions contained in Chapter V (Sections 528        E
to 560), which deal with proof and ranking of claims are
applicable to every mode of winding up. Section 528 lays down
that in every winding up, all debts payable on a contingency; and
all claims against the company,,.-present or future, certain or
contingent, ascertained or sounding only in damages, shall be       F
admissible to proof against the company. This is subject to the
rider that in the case of insolvent companies, law o{ insolvency
will be applicable in accordance with the pro"'isi~ns of the
Companies Act. Section 529 deals with application of
insolvency rules in winding up of insolvent companies. Section      G
530, as it existed prior to the amendment of the Companies Act
by Act No.35 of 1985, gave priority to revenue of the State and
local authorities and various amounts payable to employees
including the dues payable from a provident fund, a pension fund,
a gratuity fund or any other fund maintained by the company for     H
    356      SUPREME COURT REPORTS (2011] 15 (ADDL.) S.C.R.

A the welfare of the employees. By the Companies (Amendment)
  Act No.35 of 1985, proviso was added to Section 529(1). By
  the same amendment, Sections 529(3) and 529A were inserted
  in the Companies Act. Simultaneously, the expression "subject
  to the provisions of Section 529A" was inserted in Section
B 530(1). Paragraph 2 of the Statement of Objects and Reasons
  contained in the Companies (Amendment) Bill, 1985 reads as
  under:

           "2. Another announcement made by the Finance Minister
          ·in his Budget speech relates to the decision of the
c          Government to introduce necessary legislation so ~hat
           legitimate dues of workers rank pari passu with secured
           creditors in the event of closure of the company and above
           even the dues to Government. The resources of companies
           constitute a major segment of the material resources of the
D          community and common good demands that the ownership
           and control of the resources of every company are so
           distributed that in the unfortunate event of its liquidation,
           workers, whose labour and effort constitute an invisible but
           easily perceivable part of the capital of the company are
E          not deprived of their legitimate right to participate in the
           produce of their labour and effort. It is accordingly
           proposed to amend Sections 529 and 530 of the
           Companies Act and also to incorporate a new section in
           the Act, namely, Section 529-A (vide clauses 4, 5 and 6
F          of the Bill)."

         20. Sections 529(1) and (3) and 529A and the relevant
    parts of Section 530, as they stand after the 1985 amendments
    read as under:

G         "529. Application of insolvency rules in winding up of
          insolvent companies. - (1) In the winding up of an
          insolvent company, the same rules shall prevail and be
          observed with regard to-

H         (a) debts provable;
EMPLOYEES PROVIDENT FUND COMMNR. v. O.L. OF 357
 ESSKAY PHARMACEUTICALS LTD. [G.S. SINGHVI, J.]
  (b) the valuation of annuities and future and contingent        A
  liabilities; and

  (c) the respective rights of secured and unsecured
  creditors; as are in force for the time being under the law
  of insolvency with respect to the estates of persons            B
  adjudged insolvent:

  Provided that the security of every secured creditor shall
  be deemed to be subject to a pari passu charge in favour
  of the workmen to the extent of the workmen's portion
  therein, and, where a secured creditor, instead of              C
  relinquishing his security and proving his debt, opts to
  realise his security,-

  (a) the liquidator shall be entitled to represent the workmen
  and enforce such charge;                                        D

  (b) any amount realised by the liquidator by way of
  enforcement of such charge shall be applied rateably for
  the discharge of workmen's dues; and

  (c) so much of the debt due to such secured creditor as         E
  could not be realised by him by virtue of the foregoing
  provisions of this proviso or the amount of the workmen's
  portion in his security, whichever is less, shall rank pari
  passu with the workmen's dues for the purposes of section
  529A.                                                           F

  529(3). For the J..'Jrposes of this ~ection, section 529A and
  section 530,-

   (a)   "workmen'', in relation to a company, means the
         employees of the company, being workmen within           G
         the meaning of the Industrial Disputes Act, 1947 (14
         of 1947);

   (b)   "workmen's dues", in relation to a company, means
                                                                  H
    358   SUPREME COURT REPORTS (2011] 15 (ADDL.) S.C.R.


A             the aggregate of the following sums due from the
              company to its workmen, namely:-
              (i)      all wages or salary including wages payable
                       for time or piece work and salary earned
                       wholly or in part by way of commission of any
B
                       workman, in respect of services rendered to
                       the company and any compensation payable
                       to any workman under any of the provisions
                       of the Industrial Disputes Act, 1947 (14 of
                       1947);
c
              (ii)    all accrued holiday remuneration becoming
                      payable to any workman, or in the case of his
                      death to any other person in his right, on the
                      termination of his employment before, or by
D                     the effect of, the winding up order or
                      resolution;
              (iii)    unless the company is being wound up
                       voluntarily merely for the purposes of
E
                       reconstruction or of amalgamation with
                       another company, or unless the company
                       has, at the commencement of the winding
                       up, under such a contract with insurers as is
                      mentioned in section 14 of the Workmen's
                      Compensation Act, 1923 (8 of 1923) rights
F                     capable of being transferred to and vested
                      in the workman, all amounts due in respect
                      of any compensation or liability for
                      compensation under the said Act in respect
                      of the death or disablement of any workman
G                     of the company;
             (iv)     all sums due to any workman from a
                      provident fund, a pension fund, a gratuity fund
                      or any other fund for the welfare of the
H                     workmen, maintained by the company;
EMPLOYEES PROVIDENT FUND COMMNR. v. O.L. OF 359
 ESSKAY PHARMACEUTICALS LTD. [G.S. SINGHVI, J.]

   529A. Overridingpreferential payment.-(1) Notwith-            A
   standing anything contained in any other provision of this
   Act or any other law for the time being in force, in the
   winding up of a company-

          (a)   workmen's dues; and
                                                                 B
          (b)   debts due to secured creditors to the extent
                such debts rank under clause (c) of the
                proviso to sub-section (1) of section 529 pari
                passu with such dues,
                                                                 c
  shall be paid in priority to all other debts.

  (2) The debts payable under clause (a) and clause (b) of
  sub-section (1) shall be paid in full, unless the assets are
  insufficient to meet them, in which case they shall abate      D
  in equal proportions.

  530. Preferential payments.- (1) In a winding up subject
  to the provisions of section 529A, there shall be paid in
  priority to all other debts-
                                                                 E
    (a)   all revenues taxes, cesses and rates due from the
          company to the Central or a State Government or
          to a local authority at the relevant date as defined
          in clause (c) of the sub-section (8), and having
          become due and payable within the twelve months        F
          next before that date;

   (b)    all wages or salary (including wages payable for
          time or piece work and salary earned wholly or in
          part by way of commission) of any employee, in
          respect of services rendered to the company and        G
          due for a period not exceeding four months within
          the twelve months next before the relevant date
          subject to the limit specified in sub-section (2);

   (f)    all sums due to any employee from a provident fund,    H
    360     SUPREME COURT REPORTS [2011] 15 (ADDL.) S.C.R.


A                a pension fund, a gratuity fund or any other fund for
                 the welfare of the employees maintained by the
                 company;
          (2) The sum to which priority is to be given under clause
          (b) of sub-section (1 ), shall not, in the case of any one
B
          claimant, exceed such sum as may be notified by the
          Central Government in the Official Gazette."

        21. By inserting proviso in Section 529(1 ), Parliament
   ensured protection of the interest of the workmen in winding up
C proceedings. The object of this amendment is to place the
   legitimate dues of workers at par with those of secured
   creditors. This is also a legislative recognition of the fact that
   the workmen contribute to the growth of the capital and industry
   and in the event of winding up of the company, they are entitled
D to get their legitimate share in the assets of the company by
   being treated at par with other secured creditors. With the
   insertion of Section 529(3)(a), the definition of the term
   'workmen' contained in the Industrial Disputes Act, 1947 has
   been incorporated in the Companies Act for the purposes of
E Sections 529 529A and 530. The expression "workmen's
   dues" has been defined in Section 529(3)(b) to mean all wages
   or salary including wages payable for time or piece work and
   salary earned wholly or in part by way of commission of any
  workman in respect of services rendered to the company and
F any compensation payable to any workman under the Industrial
   Disputes Act, 1947, all accrued holiday remuneration payable
  to any workman, or in the case of his death to any other person
  in his right upon the termination of his employment before the
  passing of winding up order and all sums due to any workman
  from a provident fund, a pension fund, a gratuity fund or any
G other fund for the welfare of the workmen, which is maintained
  by the company. The definition also takes within its fold funds
  capable of being transferred to and vested in the workman
  under a contract with insurers under Section 14 of the
  Workmen's Compensation Act as also the amounts due in
H respect of any compensation or liability for compensation under
 EMPLOYEES PROVIDENT FUND COMMNR v. O.L. OF 361
  ESSKAY PHARMACEUTICALS LTD. [G.S. SINGHVI, J.]

the Workmen's Compensation Act in respect of the death or                 A
disablement of any workman of the company. By virtue of the
non obstante clause contained in sub-section (1) of Section
529A, statutory priority has been given to the workmen's dues
and debts due to secured creditors over all other dues.
                                                                          B
     22. The EPF Act is a social welfare legislation intended
to protect the interest of a weaker section of the society, i.e.
the workers employed in factoFies-and-other establishments,
who have made significant contribution in economic growth of
the country. The workers and other employees provide services
of different kinds and ensure continuous production of goods,             C
which are made available to the society at large. Therefore, a
legislation made for their benefit must receive a liberal and
purposive interpretation keeping in view the Directive Principles
of State Policy contained in Articles 38 and 43 of the
Constitution. In Organo Chemical Industries v. Union of India             D
(1979) 4 SCC 573, this Court negatived challenge to the
constitutionality of Section 14-B of the EPF Act. In the main
judgment delivered by him, A.P. Sen, J. referred to the
Statement of Objects and Reasons contained in the Bill
presented before Parliament, which led to the enactment of                E
Amendment Act No. 40/1973 and observed:

    "Each word, phrase or sentence is to be considered in the
    light of general purpose of the Act itself. A bare mechanical
    interpretation of the words "devoid of-concept or purpose"            F
    will reduce must of legislation to futility. It is a salutary rule,
    well established, that the intention of the legislature must
    be found by reading the statute as a whole."

     In his concurring judgment, Krishna Iyer, J. observed:
                                                                          G
     "The measure was enacted for the support of a weaker
     sector viz. the working class during the superannuated
     winter of their life. The financial reservoir for the distribution
     of benefits is filled by the employer collecting, by deducting
     from the workers' wages, completing it with his own equal            H
    362 SUPREME COURT REPORTS (2011] 15 (ADDL.) S.C.R.

A       share and duly making over the gross sums to the Fund. If
        the employer neglects to remit or diverts the moneys for
        alien purposes the Fund gets dry and the retirees are
        denied the meagre support when they most need it. This
        prospect of destitution demoralises the working class and
B       frustrates the hopes of the community itself. The whole
        project gets stultified if employers thwart contributory
        responsibility and this wider fall-out must colour the concept
        of 'damages' when the court seeks to define its content in
        the special setting of the Act. For, judicial interpretation
c       must further the purpose of a statute. In a different context
        and considering a fundamental treaty, the European Court
        of Human Rights, in the Sunday Times Case, observed:

               The Court must interpret them in a way that
               reconciles them as far as possible and is most
D              appropriate in order to realise the aim and achieve
               the object of the treaty.

        A policy-oriented interpretation, when a welfare legislation
        falls for determination, especially in the context of a
E       developing country, is sanctioned by principle and
        precedent and is implicit in Article 37 of the Constitution
        since the judicial branch is, in a sense, part of the State.
        So it is reasonable to assign to 'damages' a larger,
        fulfilling meaning."
F        23. Section 11 (2) of the EPF Act was interpreted by the
    Division Bench of the Kera/a High Court in Recovery Officer
    and Asstt. Provident Fund Commissioner v. Kera/a Financial
    Corporation, ILR (2002) 3 Kerala 4. Speaking for the Bench,
    B.N. Srikrishna, J. (as he then was) observed:
G
        "The F.P.F. and M.P. Act, 1952 is an Actto provide for the
        institution of Provident Fund, Pension Fund, Deposit
        Linked Insurance Fund etc. in factories and other
        establishments, to carry forward the Constitutional
H       mandate of rendering social justice to the working class.
EMPLOYEES PROVIDENT FUND COMMNR. v. O.L. OF 363
 ESSKAY PHARMACEUTICALS LTD. [G.S. SINGHVI, J.]
   It is intended to give social security to industrial workers A
   at the end of their careers. The E.P.F. and M.P. Act
   requires every employer to deduct certain prescribed
   amounts from the wages payable to employees along with
   prescribed contribution by the employer and deposit such
   contributions in the Provident Fund. The Provident jis B
   administered by the Central and Regional Provident Fund
   Commissioners, who are statutory authorities. What is of
   importance to us is that section 11 of E.P.F. and M.P. Act,
   declares the priority of payment of contributions under the
   Act over other debts. Sub-section (1) of section 11 of E.P.F. c
   and M.P. Act deals with the question of priority where an
   employer is adjudicated insolvent or being a company
   subjected to an order of winding up. Sub-section (2) of
   section 11 deals with other types of priorities and reads
   as under:
                                                                 D
            "11 (2) Without prejudice to the provisions of sub-
            section (1), if any amount is due from an employer,
            whether in respect of the employee's contribution
            deducted from the wages of the employee or the
            employer's contribution, the amount so due shall be E
            deemed to be the first charge on the assets of the
            establishment, and shall, notwithstanding anything
            contained in any other law, for the time being in
            force, be paid in priority to all other debts."
                                                                    F
   Sub-section (2) of section 11 of the E.P.P. and M.P. Act
   has two facets. First, it declares that the amount due from
   the employer towards contribution under the E.P.F. and
   M.P. Act shall be deemed to be a first charge on the
   assets of the establishment. Second, it also declares that       G
   notwithstanding anything contained in any other law for the
   time being in force, such debt shall be paid in priority to
   all other debts. Both these provisions bring out the intention
   of Parliament to ensure the social benefit as contained in
   the legislation. There are other provisions in 'the Act          H
    364     SUPREME COURT REPORTS [2011] 15 (ADDL.) S.C.R.


A         rendering the amounts of Provident Fund payable immune
          from attachment of Civil Court's decree, which also
          indicate such intention of Parliament."
       24. The ratio of the afore-mentioned judgment has been
B noticed in Central Bank of India v. State of Kera/a (2009) 4
  SCC 94 and Maharashtra State Cooperative Bank Ltd. v.
  Assistant Provident Fund Commissioner (2009) 10 SCC 123.

       25. The nature of priority given to the taxes payable to the
  State over other debts was considered by the Constitution
C Bench in Builders Supply Corporation v. Union of India (1965)
  2 SCR 289. After noticing the judgments of the Bombay and
  Madras High Courts, the Constitution Bench held:

          "(i) The common law doctrine of the priority of Crown debts
D         had a wide sweep but the question in the present appeal
          was the narrow one whether the Union of India was entitled
          to claim that the recovery of the amount of tax due to it from
          a citizen must take precedence and priority over unsecured
          debts due from the said citizen to his other private
          creditors. The weight of authority in India was strongly in
E
          support of the priority of tax dues.

          (ii) The common law doctrine on which the Union of India
        based its claim in the present proceedings had been
        applied and upheld in that part of India which was known
F      as 'British India' prior to the Constitution. The rules of
       common law relating to substantive rights which had been
       adopted by this country and enforced by judicial decisions,
       amount to 'law in force' in the territory of India at the
       relevant time within the meaning of Article 372(1 ). In that
G      view of the matter, the contention of the appellant that after
       the Constitution was adopted the position of the Union of
       India in regard to its claim for priority in the present
       proceedings had been alerted could not be upheld.

       (iii) The basic justification for the claim for priority of
H
EMPLOYEES PROVIDENT FUND COMMNR. v. O.L. OF 365
 ESSKAY PHARMACEUTICALS LTD. [G.S. SINGHVI, J.]

    government debts rests on the well-recognised principle          A
    that the State is entitled to raise money by taxation,
    otherwise it will not be able to function as a sovereign
    Government at all. This consideration emphasises the
    necessity and wisdom of conceding to the State the right
    to claim priority in respect of its tax dues."                   B

                                           (emphasis supplied)

     26. The ratio of the judgment in Builders Supply
Corporation v. Union of India (supra) was applied to the cases
in which statutory first charge was created in favour of the State   C
in the matter of recovery of tax, penalty, interest etc.. - State
Bank of Bikaner and Jaipur v. National Iron and Steel Rolling
Corporation (1995) 2 SCC 19, Dena Bank v. Bhikhabhai
Prabhudas Parekh & Co. (2000) 5 SCC 694 and State of M.P.
v. State Bank of Indore (2002) 10 SCC 441. In the last               D
mentioned judgment, i.e. State of M.P. v. State Bank of Indore
(supra), this Court considered the question whether statutory
first charge created under Section 33-C of the M.P. General
Sales Tax Act, 1958 would prevail over the bank's charge and
held:                                                                E

     "Section 33-C creates a statutory first charge that prevails
     over any charge that may be in existence. Therefore, the
     charge thereby created in favour of the State in respect
     of the sales tax dues of the second respondent prevailed        F
     over the charge created in favour of the Bank in respect
     of the Joan taken by the second respondent. There is no
     question of retrospectivity here, as, on the date when it was
     introduced, Section 33-C operated in respect of all
     charges that were then in force and gave sales tax dues
     precedence over them."                                          G

                                            (emphasis supplied)

    27. At this juncture, it will be apposite to mention that the
nature of statutory first charge and the rule of priority of the     H
    366    SUPREME COURT REPORTS [2011] 15 (ADDL.) S.C.R.


A State's dues were considered in Builders Supply Corporation
    v. Union of India (supra), State Bank of Bikaner and Jaipur v.
   National Iron and Steel Rolling Corporation (supra), Dena
   Bank v. Bhikhabhai Prabhudas Parekh & Co. (supra) and
   State of M.P. v. State Bank of Indore (supra) in the context of
B contra claim made by unsecured creditors. The question
  whether first charge created by taxing statutes enacted by State
   legislatures will prevail over the debts due to secured creditors
  was considered by a three Judge Bench in Central Bank of
   India v. State of Kera/a (supra) and answered in affirmative. In
c that case, this Court was called upon to consider whether the
  first charge created on the property of the dealer by the
   legislations enacted by State legislatures for levy and collection
  of sales tax would prevail over the debts due to banks, financial
  institutions and other secured creditors, which could be
  recovered under the Recovery of Debts Due to Banks and
0
  Financial Institutions Act, 1993 and/or the Securitisation and
  Reconstruction of Financial Assets and Enforcement of Security
  Interest Act, 2002. The Court referred to the relevant provisions
  contained in the ORT Act, the Securitisation Act and Sales Tax
  legislations of different States as also Section 14A of the
E Workmen's Compensation Act, 1923, Section 11 of the EPF
  Act, Section 74 of the Estate Duty Act, 1953, Section 25 of the
  Mines and Minerals (Regulation and Development) Act, 1957,
  Section 30 of the Gift Tax Act, 1958, Section 529A of the
  Companies Act, 1956, Section 46B of the State Financial
F Corporations Act, 1951 and observed:

        "Under Section 13(1) of the Securitisation Act, limited
        primacy has been given to the right of a secured creditor
       to enforce security interest vis-a-vis Section 69 or Section
G      69-A of the Transfer of Property Act. In terms of that sub-
       section, a secured creditor can enforce security interest
       without intervention of the court or tribunal and if the
       borrower has created any mortgage of the secured asset,
       the mortgagee or any person acting on his behalf cannot
H      sell the mortgaged property or appoint a Receiver of the
EMPLOYEES PROVIDENT FUND COMMNR. v. O.L. OF 367
 ESSKAY PHARMACEUTICALS LTD. [G.S. SINGHVI, J.]

   income of the mortgaged property or any part thereof in a     A
   manner which may defeat the right of the secured creditor
   to enforce security interest. This provision was enacted in
   the backdrop of Chapter VIII of the Narasimham
   Committee's Second Report in which specific reference
   was made to the provisions relating to mortgages under        B
   the Transfer of Property Act.

   In an apparent bid to overcome the likely difficulty faced
   by the secured creditor which may include a bank or a
   financial institution, Parliament incorporated the non C
   obstante clause in Section 13 and gave primacy to the right
   of secured creditor vis-a-vis other mortgagees who could
   exercise rights under Sections 69 or 69-A of the Transfer
   of Property Act._However, this primacy has not been
   extended to other provisions like Section 38-C of the
   Bombay Act and Section 26-8 of the Kera/a Act by which D
   first charge has been created in favour of the SttJte over
   the property of the dealer or any person liable to pay the
   dues of sales tax, etc. Sub-section (7) of Section 13 which
   envisages application of the money received by the
   secured creditor by adopt\ng any of the measures E
   specified under sub-section (4) merely regulates
   distribution of money received by the secured creditor. It
    does not create first charge in favour of the secured
    creditor.
                                                                 F
   By enacting various provisos to sub-section (9) of Section
   13, the legislature has ensured that priority given to the
   claim of workers of a company in liquidation under Section
   529-A of the Companies Act, 1956 vis-a-vis the secured
   creditors like banks is duly respected. This is the reason G
   why first of the five unnumbered provisos to Section 13(9)
   lays down that in the case of a company in liquidation, the
   amount realised from the sale of secured assets shall be
   distributed in accordance with the provisions of Section
   529-A of the Companies Act, 1956. This and other H
    368     SUPREME COURT REPORTS (2011] 15 (ADDL.) S.C.R.


A         provisos do not create first charge in favour of the worker
          of a company in liquidation for the first time but merely
          recognise the existing priority of their claim under the
          Companies Act. It is interesting to note that the provisos
          to sub-section (9) of Section 13 do not deal with the
B         companies which fall in the category of borrower but which
          are not in liquidation or are not being wound up.

          It is thus clear that provisos referred to above are only part
          of the distribution mechanism evolved by the legislature
          and are intended to protect and preserve the right of the
c         workers of a company in liquidation whose assets are
          subjected to the provisions of the Securitisation Act and
          are disposed of by the secured creditor in accordance with
          Section 13 thereof."

D                                                (emphasis supplied)
               .                                            .
        28. The Court then referred to the earlier judgments in
   Builders Supply Corporation v. Union of India (supra), State
  Bank of Bikaner and Jaipur v. National Iron and Steel Rolling
E Corporation (supra), Dena Bank v. Bhikhabhai Prabhudas
  Parekh & Co. (supra), State of M.P. v. State Bank of Indore
  (supra), Allahabad Bank v. Canara Bank (2000) 4 SCC 406,
  the judgment of the Division Bench of the Kera la High Court in
  Recovery Officer and Asstt. Provident Fund Commissioner v.
F Kera/a Financial Corporation (supra) and observed:

       "While enacting the ORT Act and the Securitisation Act,
       Parliament was aware of the law laid down by this Court
       wherein priority of the State dues was recognised. If
       Parliament intended to create first charge in favour of
G      banks, financial institutions or other secured creditors on
       the property of the borrower, then it would have
       incorporated a provision like Section 529-A of the
       Companies Act or Section 11(2) of the EPF Act and
       ensured that notwithstanding series of judicial
H      pronouncements, dues of banks, financial institutions and
EMPLOYEES PROVIDENT FUND COMMNR. v. O.L. OF 369
 ESSKAY PHARMACEUTICALS LTD. [G.S. SINGHVI, J.]

  other secured creditors should have priority over the State's A
  statutory first charge in the matter of recovery of the dues
  of sales tax, etc. However, the fact of the matter is that no
  such provision has been incorporated in either of these
  enactments despite conferment of extraordinary power
  upon the secured creditors to take possession and B
  dispose of the secured assets without the intervention of
  the court or Tribunal. The reason for this omission appears
  to be that the new legal regime envisages transfer of
  secured assets to private companies.

   The definition of "secured creditor" includes securitisation/ c
   reconstruction company and any other trustee holding
   securities on behalf of bank/financial institution. The
   definition of "securitisation company" and "reconstruction
   company" in Sections 2(1)(za) and (v) shows that these
   companies may be private companies registered under D
   the Companies Act, 1956 and having a certificate of
   registration from Reserve Bank under Section 3 of the
   Securitisation Act. Evidently, Parliament did not intend to
   give priority to the dues of private creditors over sovereign
   debt of the State.                                            E

   If the provisions of the DRT Act and the Securitisation Act
   are interpreted keeping in view the background and context
   in which these legislations were enacted and the purpose
   sought to be achieved by their enactment, it becomes F
   clear that the two legislations, are intended to create a new
   dispensation for expeditious recovery of dues of banks,
   financial institutions and secured creditors and
    adjudication of the crievance made by any aggrieved
    person qua the procedure adopted by the banks, financial G
    institutions and other secured creditors, but the provisions
    contained therein cannot be read as creating first charge
    in favour of banks, etc.
    If Parliament intended to give priority to the dues of banks,
    financial institutions and other secured creditors over the     H
    370     SUPREME COURT REPORTS (2011] 15 (ADDL.) S.C.R.


A         first charge created under State legislations then
          provisions similar to those contained in Section 14-A of
          the Workmen's Compensation Act, 1923, Section 11 (2)
          of the EPF Act, Section 74(1) of the Estate Duty Act, 1953,
          Section 25(2) of the Mines and Minerals (Regulation and
B         Development) Act, 1957, Section 30 of the Gift Tax Act,
          and Section 529-A of the Companies Act, 1956 would
          have been incorporated in the ORT Act and the
          Securitisation Act.

       Undisputedly, the two enactments do not contain provision
c      similar to the Workmen's Compensation Act, etc. In the
       absence of any specific provision to that effect, it is not
       possible to read any conflict or inconsistency or
       overlapping between the provisions of the ORT Act and
      the Securitisation Act on the one hand and Section 38-C
0     of the Bombay Act and Section 26-B of the Kerala Act on
      the other and the non·obstante clauses contained in
      Section 34(1) of the ORT Act and Section 35 of the
      Securitisation Act cannot be invoked for declaring that the
      first charge created under the State legislation will not
E     operate qua or affect the proceedings initiated by banks,
      financial institutions and other secured creditors for
      recovery of their dues or enforcement of security interest,
      as the case may be.

       The Court could have given effect to the non obstante
F
      clauses contained in Section 34(1) of the ORT Act and
      Section 35 of the Securitisation Act vis-a-vis Section 38-
      C of the Bombay Act and Section 26-B of the Kerala Act
      and similar other State legislations only if there was a
      specific provision in the two enactments creating first
G
      charge in favour of the banks, financial institutions and
      other secured creditors but as Parliament has not made
      any such provision in either of the enactments, the first
      charge created by· the State legislations on the property
      of the dealer or any other person, liable to pay sales tax,
H
 EMPLOYEES PROVIDENT FUND COMMNR. v. O.L. OF 371
  ESSKAY PHARMACEUTICALS LTD. [G.S. SINGHVI, J.]

     etc., cannot be destroyed by implication or inference, A
     notwithstanding the fact that banks, etc. fall in the category
     of secured creditors."

                                          (emphasis supplied)

        29. In Maharashtra State Cooperative Bank Ltd. v. B
  Assistant Provident Fund Co;nmissioner (supra), the Court
 was called upon to consider whether dues payable by the
  employer under Section 11 of the EPF Act will have priority over
  debts due to the bank. The facts of that case were that Kannad
  Sahakari Sakhar Karkhana Ltd. and Gangapur Sahakari C
  Sakhar Karkhana Ltd. had pledged sugar bags in favour of the
  appellant bank as security for repayment of the loan and
  interest. The respondent initiated proceedings for recovery of
  the dues payable under the EPF Act. The appellant bank
  questioned the legality of the orders passed under the EPF Act D
  on the ground that being a secured creditor, the -amount due
  to it was payable on priority vis-a-vis other dues including the
  dues payable by the employer under the EPF Act. The High
  Court negatived the challenge. The Court referred to the
   relevant provisions of the EPF Aclincluding Section 11, the E
· judgments noticed hereinabove as also the judgments in UCO
   Bank v. Official Liquidator, High Court of Bombay (1994) 5
   SCC 1, AP. State Financial Corporation v. Official Liquidator
   (2000) 7 SCC 291, Textile Labour Association v. Official
   Liquidator (2004) 9 SCC 741 and held:                           F

      "The priority given to the dues of provident fund, etc. in
      Section 11 is not hedged with any limitation or condition.
      Rather, a bare reading of the section makes it clear that
      the amount due is required to be paid in priority to all
      other debts. Any doubt on the width and scope of Section G
      11 qua other debts is removed by the use of expression
      "all other debts" in both the sub-sections. This would
      mean that the priority clause enshrined in Section 11 will
       operate against statutory as well as non-statutory and
       secured as well as unsecured debts including a mortgage H
     372     SUPREME COURT REPORTS [2011] 15 (ADDL) S.C.R.


 A         or pledge. Sub-section (2) was designedly inserted in the
            Act for ensuring that the provident fund dues of the
            workers are not defeated by prior claims of secured or
           unsecured creditors. This is the reason why the legislature
           took care to declare that irrespective of time when a debt
 B         is created in respect of the assets of the establishment,
           the dues payable under the Act would always remain first
           charge and shall be paid first out of the assets of the
           establishment notwithstanding anything contained in any
           other law for the time being in force. It is, therefore,
           reasonable to take the view that the statutory first charge
 c
           created on the assets of the establishment by sub-section
           (2) of Section 11 and priority given to the payment of any
           amount due from an employer will operate against all types
           of debts."

 D                                              (emphasis supplied)

          30. The ratio for the last mentioned judgment is that by
     virtue of the non obstante clause contained in Section 11 (2)
     of the EPF Act, any amount due from an employer shall be
 E   deemed to be first charge on the assets of the establishment
     and is payable in priority to all other debts including the debts
     due to a bank, which falls in the category of secured creditor.

         31. We may now notice some judgments which have
    bearing on the interpretation of Sections 529 or 529A of the
 F Companies Act. The scope of proviso to sub-section (1) of
    Section 529 (as inserted by Amendment Act No.35 of 1985)
   was examined in UCO Bank v. Official Liquidator, High Court,
   Bombay (1994) 5 SCC 1. The facts of that case were that in
   Company Petition No.27 of 1971, the learned Company Judge
G of the Bombay High Court made an order dated 15.11.1972
   for winding up of M/s. Glass Carboys and Pressedwares
   Limited. The Official Liquidator took possession of the assets
   of the company. Appellant - UCO Bank, Which was a secured
   creditor of the company obtained a decree on 22.4.1976 for
H recovery of its debt. Thereafter, the High Court's Commissioner
EMPLOYEES PROVIDENT FUND COMMNR. v. O.L. OF 373
 ESSKAY PHARMACEUTICALS LTD. [G.S. SINGHVI, J.]
for taking accounts was directed to sell certain movables of the A
company. In the meantime, the Companies Act was amended
by Act No.35 of 1985 and Sections 529 and 530 were
amended and Section 529A was inserted. It was argued on
behalf of the appellant that the amendment was not applicable
to its case because the decree had been passed before the B
amendment and being a secured creditor, it was entitled to
realize its debt in priority to other dues. The learned Company
Judge accepted the argument but he was overruled by the
 Division Bench. While dealing with the argument, which found
favour with the learned Company Judge, this Court referred to c
the Stat•;ment of Objects and Reasons contained in the Bill and
 observed:

     "The proviso to sub-section (1) of Section 529 inserted by
     the Amending Act clearly provides that "the security of
     every secured creditor shall be deemed to be subject to        D
     a pari passu charge in favour of the workmen". The effect
     of the proviso is to create, by statute, a charge pari passu
     in favour of the workmen on every security available to
     the secured creditors of the employer company for
     recovery of their debts at the time when the amendment         E
     came into force. This expression is wide enough to apply
     to the security of every secured creditor which remained
     unrealised on the date of the amendment. The clear object
     of the amendment is that the legitimate dues of workers
     must rank pari passu with those of secured creditors and · F
     above even the dues of the Government. This literal
     construction of the proviso is in consonance with, and
     promotes, the avowed object of the amendment made. On
     the contrary, the construction of the proviso suggested by
     the learned counsel for the appellant, apart from being in     G
     conflict with the plain language of the proviso also defeats
     the object of the legislation.
      A debt due to a secured creditor, when recovered by
      realisation of the security after commencement of the         H
     374    SUPREME COURT REPORTS [2011] 15 (ADDL.) S.C.R.


 A         winding up proceedings, results in depletion of the assets
           in the hands of the Official Liquidator. This provision is
           intended to protect the interests of the workmen in
           proceedings for winding up. In view of the nature of
           workmen's dues being similar to those of secured
 B         creditors, the purpose of this provision is to place the
           workmen on a par with the secured creditors and create
          a statutory charge in their favour on all available
          securities forming part of the assets of the company in
          liquidation so that the workmen also share the securities
 c        pari passu with the secured creditors. The workmen
          contribute to the growth of the capital and must get their
          legitimate share in the assets of the company when the
          situation arises for its closure and distribution of its
          assets first among the secured creditors due to winding
         up of the company. The aforesaid amendment made in
 D
         the Act is a statutory recognition of this principle equating
         the legitimate dues of the workmen with the debts of the
         secured creditors of the company. To achieve this purpose,
         it is necessary that the amended provision must apply to
         all available securities which form part of the assets of the
 E       company in liquidation on the date of the amendment. The
         conclusion reached by the Division Bench of the High
         Court is supported by this reason."

                                               (emphasis supplied)
F
        32. In Allahabad Bank v. Canara Bank (supra), a two-
   Judge Bench was called upon to consider the question whether
   an application can be filed under the Companies Act, 1956
   during the pendency of proceedings under the ORT Act. The
G facts of that case show that Allahabad Bank filed an OA before
   the Delhi Bench of the ORT under Section 19. The same was
  decreed on 13.1.1998. The debtor company filed an appeal
  before DRAT, Allahabad. Canara Bank also filed application
  under Section 19 before ORT, Delhi. During the pendency of
H its application, Canara Bank filed an interlocutory application
EMPLOYEES PROVIDENT FUND COMMNR. v. O.L. OF 375
 ESSKAY PHARMACEUTICALS LTD. (G.S. SINGHVI, J.]
before the Recovery Officer for impleadment in the proceedings A
arising out of the OA filed by Allahabad Bank. That application
was dismissed on 28.9.1998. In the auction conducted by the
Recovery Officer, the property of the debtor company was
auctioned and the sale was confirmed. Thereupon, Canara
Bank filed applications under Section 22 of the ORT Act. During B
the pendency of applications, Canara Bank filed company
application in Company Petition No. 141 of 1995 filed by
Ranbaxy Ltd. against M.S. Shoes Company under Sections
442 and 537 of the Companies Act for stay of the proceedings
of Recovery Case No. 9of1998 instituted by Allahabad Bank. c
By an order dated 9.3.1999, the learned Company Judge
stayed further sale of the assets of the company. The Allahabad
Bank challenged the order of the learned Company Judge and
pleaded that in view of the amendment made in Section 19(19)
of the ORT Act, Section 529A is attracted for a limited purpose,
                                                                 0
i.e_. recovery of the dues of workmen. While dealing with this
plea, the Court observed as under:

     "The respondent's contention that Section 19(19) gives
     priority to all 'secured creditors' to share in the sale
     proceeds before the Tribuna1/ Recovery Officer cannot, in        E
     our opinion, be accepted. The said words are qualified by
     the words 'in accordance with the provision of Section 529-
     A'. Hence, it is necessary to identify the above limited class
     of secured creditors who have priority over all others in
     accordance with Section 529-A.                                   F

     Secured creditors fall under two categories. Those who
     desire to go before the Company Court and those who like
     to stand outside the winding up.

     The first category of secured creditors mentioned above          G
     are those who go before the Company Court for dividend
     by relinquishing their security in accordance with the
     insolvency rules mentioned in Section 529. The insolvency
     rules are those contained in Sections 45 to 50 of the
     Provincial Insolvency Act. Section 47(2) of that Act states      H
     376    SUPREME COURT REPORTS [2011] 15 (ADDL.) S.C.R.


 A         that a secured creditor who wishes to come before the
           Official Liquidator has to prove his debt and he can prove
           his debt only if he relinquishes his security for the benefit
           of the general body of creditors. In that event, he will rank
           with the unsecured creditors and has to take his dividend
 B         as provided in Section 529(2). Till today, Canara Bank has
         · not made it clear whether it wants to come under this
           category.

          The second class of secured creditors referred to above
          are those who come under Section 529-A(1)(b) read with
 c        proviso (c) to Section 529(1). These are those who opt to
          stand outside the winding up to realise their security.
          Inasmuch as Section 19(19) permits distribution to
          secured creditors only in accordance with Section 529-A,
          the said category is the one consisting of creditors who
 D        stand outside the winding up. These secured creditors in
          certain circumstances can come before the Company
          Court (here, the Tribunal) and claim priority over all other
         creditors for release of amounts out of the other monies
         lying in the Company Court (here, the Tribunal). This limited
E        priority is declared in Section 529-A(1) but it is restricted
         only to the extent specified in clause (b) of Section 529-
         A(1). The said provision refers to clause (c) of the proviso
         to Section 529(1) and it is necessary to understand the
         scope of the said provision."
F
        33. The judgment in Allabahad Bank v. Canara Bank
   (supra) was distinguished by a two-Judge Bench judgment in
   /CIC/ Bank Ltd. v. S!DCO Leathers Ltd. (2006) 10 SCC 452.
   In that case, the appellant and Punjab National Bank had
G advanced loans to respondent No. 1 for setting up a plant for
  manufacture of leather boards and for providing working capital
  funds respectively. Respondent No.1 created first charge in
  favour of the appellant along with other financial institutions, i.e.
  IFCI and IDBI by way of equitable mortgage by deposit of title
H deeds of its immovable property. A second charge was
 EMPLOYEES PROVIDENT FUND COMMNR. v. O.L. OF 377
  ESSKAY PHARMACEUTICALS LTD. [G.S. SINGHVI, J.]

created in favour of Punjab National Bank by way of                     A
constructive delivery of title deeds, clearly indicating therein that
the charge in favour of the latter was subject to and subservient
to charges in favour of IFCI, IDBI and ICICI. On an application
filed by respondent No.1, the Allahabad High Court passed
winding up order and appointed Official Liquidator. Thereafter,         B
the appellant filed a suit for recovery of the amount credited to
respondent. In due course, the suit was transferred to Debts
Recovery Tribunal, Bombay. During the pendency of the
proceedings before the Tribunal, the Official Liquidator was
granted permission to continue the proceedings of the suit. Civil       C
Judge, Fatehpur before whom the suit was pending, ordered
sale of the assets of the company. At that stage, the appellants,
IFCI and IDBI jointly filed an application before the Company
Judge for considering their claim on pro rata basis and also
for exclusion of the claim of the Punjab National Bank. The
learned Company Judge accepted the first prayer of the                  D
appellant but rejected the second one by relying upon the
judgment in Allahabad Bank v. Canara Bank (supra). The intra
Court appeal was dismissed by the Division Bench by relying
upon Section 529A of the Companies Act. On further appeal,
this Court distinguished the judgment in Allahabad Bank v.              E
Canara Bank by relying upon an earlier judgment in Rajasthan
State Financial Corporation v. Official Liquidator (2005) 8
sec 190 and observed:
     "In fact in Allahabad Bank it was categorically held that the      F
     adjudication officer would have such powers to distribute
     the sale proceeds to the banks and financial institutions,
     being secured creditors, in accordance with inter se
     agreemenUarrangement between them and to the other
     persons entitled thereto in accordance with the priority in        G
     law.

     Section 529-A of the Companies Act no doubt contains a
     non obstante clause but in construing the provisions
     thereof, it is necessary to determine the purport and object
     for which the same was enacted.                                    H
     378 . SUPREME COURT REPORTS (2011) 15 (ADDL) S.C R


 A       In terms of Section 529 of the Companies Act, as it stood
         prior to its amendment, the dues of the workmen were not
         treated pari passu with the secured creditors as a result
         whereof innumerable instances came to the notice of the
         Court that the workers may not get anything after
         discharging the debts of the secured creditors. It is only
 B
         with a view to bring the workmen's dues pari passu with
         the secured creditors, that Section 529-A was enacted.

         The non obstante nature of a provision although may be
         of wide amplitude, the interpretative process thereof must
 c       be kept confined to the legislative policy. Only because the
         dues of the workmen and the debts due to the secured
         creditors are treated pari passu with each other, the same
         by itself, in our considered view, would not lead to the
         conclusion that the concept of inter se priorities amongst
 D       the secured creditors had thereby been intended to be
         given a total go-by.

         A non obstante clause must be given effect to, to the extent
         Parliament intended and not beyond the same.
 E         Section 529-A of the Companies Act does not ex facie
           contain a provision (on the aspect of priority) amongst the
           secured creditors and, hence, it would not be proper to
       . re;:id there into things, which Parliament did not
        ·. comprehend:"          .       .
.F
         34. In A.P. State Financial Corporation v. Official
   Liquidator (supra), the Court rejected the argument that the
   proceedings initiated by the Financial Corporation under
   Section 29 of the State Financial Corporations Act, 1951 will
 G not be affected by the non obstante clause contained in Section
   529A of the Companies Act and observed:

         "The Act of 1951 is a special Act for grant of financial
         assistance to industrial concerns with a view to boost up
         industrialisation and also recovery of such financial
 H
EMPLOYEES PROVIDENT FUND COMMNR. v. O.L. OF 379
 ESSKAY PHARMACEUTICALS LTD. [G.S. SINGHVI, J.]
    assistance if it becomes bad and similarly the Companies A
    Act deals with companies including winding up of such
    companies. The proviso to sub-section (1) of Section 529
    and Section 529-A being a subsequent enactment, the
    non obstante clause in Section 529-A prevails over
    Section 29 of the Act of 1951 in view of the settled B
    position of Jaw. We are, therefore, of the opinion that the
    above proviso to sub-section (1) of Section 529 and
    Section 529-A will control Section 29 of the Act of 1951.
    In other words the statutory right to sell the property under
    Section 29 of the Act of 1951 has to be exercised with the c
    rights of pari passu charge to the workmen created by the
    proviso to Section 529 of the Companies Act. Under the
    proviso to sub-section (1) of Section 529, the liquidator
    shall be entitled to represent the workmen and force (sic
    enforce) the above pari passu charge. Therefore, the 0
    Company Court was fully justified in imposing the above
    conditions to enable the Official Liquidator to discharge
    his function properly under the supervision of the
    Company. Court as the new Section 529-A of the
    Companies Act confers upon a Company Court the duty           E
    to ensure that the workmen's dues are paid in priority to
    all other debts in accordance with the provisions of the
    above section. The legislature has amended the
    Companies Act in 1985 with a social purpose viz. to protect
    dues of the workmen. If conditions are not imposed to
    protect the right of the workmen there is every possibility   F
    that the secured creditor may frustrate the above pari
    passu right of the workmen."
                                         (emphasis supplied)
                                                                  G
      35. We have referred to these judgments only for the
purpose of showing that the object of the amendments made
in the Companies Act by Act No. 35 of 1985 was to ensure
that the legitimate dues of workers should rank pari passu with
those of secured creditors. In other words, these amendments H
    380     SUPREME COURT REPORTS [2011] 15 (ADDL.) S.C.R.


A   are intended to protect the interest of the workmen in winding
     up proceedings by placing them at par with secured creditors
    and a statutory charge is created qua their dues on all available
    securities forming part of the assets of the company in
    liquidation. However, the propositions laid down in these
B   judgments are of little assistance in deciding the question
    raised in these appeals because in none of the cases the Court
    considered the so called conflict in the non obstante clauses
    contained in Section 11 (2) of the EPF Act and Section 529A
    of the Companies Act.
c        36. The argument of Shri Gaurav Agrawal that the non
   obstante clause contained in the subsequent legislation, i.e.
   Section 529A(1) of the Companies Act should prevail over
  similar clause contained in an earlier legislation, i.e. Section
   11 (2) of the EPF Act sounds attractive, but if the two provisions
D are read in the light of the objects sought to be achieved by
  the legislature by enacting the same; it is not possible to agree
  with the learned counsel. As noted earlier, the object of the
  amendment made in the EPF Act by Act No.40 of 1973 was
  to treat the dues payable by the employer as first charge on
E the assets of the establishment and to ensure that the same
  are recovered in priority to other debts. As against this, the
  amendments made in the Companies Act in 1985 are intended
  to create a charge pari passu in favour of the workmen on every
  security available to the secured creditors of the company for
F recovery of their debts. There is nothing in the language of
  Section 529A which may give an indication that legislature
  wanted to create first charge in respect of the workmen's dues,
  as defined in Sections 529(3)(b) and 529A and debts due to
  the secured creditors.
G
         37. It is a well recognized rule of interpretation that every
    part of the statute must be interpreted keeping in view the
    context in which it appears and the purpose of legislation. In
    RBI v. Peerless General Finance and Investment Co. Ltd.
H   (1987) 1 SCC 424, Chinnappa Reddy, J. highlighted the
 EMPLOYEES PROVIDENT FUND COMMNR. v. O.L OF 381
  ESSKAY PHARMACEUTICALS LTD. [G.S. SINGHVI, J.]

importance of the rule of contextual interpretation in the following   A
words:

     "Interpretation must depend on the text and the context.
     They are the bases of interpretation. One may well say if
     the text is the texture, context is what gives the colour. B
     Neither can be ignored. Both are important. That
     interpretation is best which makes the textual interpretation
     match the contextual. A statute is best interpreted when we
     know why it was enacted. With this knowledge, the statute
     must be read, first as a whole and then section by section, C
     clause by clause, phrase by phrase and word by word. If .
     a statute is looked at, in the context of its enactment, with
     the glasses of the statute-maker, provided by such context,
     its scheme, the sections, clauses, phrases and words may
     take colour and appear different than when the statute is
     looked at without the glasses provided by the context. With D
     these glasses we must look at the Act as a whole and
     discover what each section, each clause, each phrase and
     each word is meant and designed to say as to fit into the
     scheme of the entire Act. No part of a statute and no word
     of a statute can be construed in isolation. Statutes have E
     to be construed so that every word has a place and
     everything is in its place."

     38. Another rule of interpretation of Statutes is that if two
special enactments contain provisions which give overriding            F
effect to the provisions contained therein, then the Court is
required to consider the purpose and the policy underlying the
two Acts and the clear intendment conveyed by the language
of the relevant provisions.
     39. In Shri Ram Narain v. Simla Banking and Industrial            G
Co. Ltd. 1956 SCR 603, this Court was considering the
provisions contained in the Banking Companies Act, 1949 and
the Displaced Persons (Debts Adjustment) Act, 1951. Both the
enactments contained provisions giving overriding effect to the
                                                                       H
    382     SUPREME COURT REPORTS [2011] 15 (ADDL.) S.C.R.

A provisions of the enactment over any other law. After noticing
  the relevant provisions, the Court observed:

          "Each enactment being a special Act, the ordinary principle
          that a special law overrides a general law does not afford
          any clear solution in this case."
B
          "It is, therefore, desirable to determine the overriding effect
          of one or the other of the relevant provisions in these two
          Acts, in a given case, on much broader considerations of
          the purpose and policy underlying the two Acts and the
c         clear intendment conveyed by the language of the relevant
          provisions therein."

       40. In Kumaon Motor Owners' Union Ltd. v. State of Uttar
  Pradesh (1966) 2 SCR 121, there was conflict between the
D provisions contained in Rule 131(2) (g) and (1) of the Defence
  of India Rul~s. 1962 and Chapter IV-A of the Motor \(ehicles
  Act, 1939. Section 68-B gave overriding effect to the provisions
  of Chapter IV-A of the Motor Vehicles Act whereas Section 43
  of the Defence of India Act, 1962, gave overriding effect to the
E provisions contained in the Defence of India Rules. This Court
  held that the Defence of India Act was later than the Motor
  Vehicles Act and, therefore, if there was anything repugnant,
  the provisions of the later Act should prevail. This Court also
  looked into object behind the two statutes, namely, Defence of
  India Act and Motor Vehicles Act and on that basis also it was
F held that the provisions contained in the Defence of India Rules
  would have an overriding effect over the provisions of the Motor
  Vehicles Act.
       41. In Ashok Marketing Limited v. Punjab National Bank
G (1990) 4 SCC 406, the Constitution Bench considered some
  of the precedents on the interpretation of statutes and observed


          "The principle which emerges from these decisions is that
          in the case of inconsistency between the provisions of two
H
EMPLOYEES PROVIDENT FUND COMMNR. v. O.L. OF 383
 ESSKAY PHARMACEUTICALS LTD. [G.S. SINGHVI, J.]
    enactments, both of which can be regarded as special A
    in nature, the conflict has to be resolved by reference to
    the purpose and policy underlying the two enactments
    and the clear intendment conveyed by the language of
    the relevant provisions therein."
                                                               B
                                          (emphasis supplied)

      42. It is also important to bear in mind that even before
the insertion of proviso to Sections 529(1 ), 529(3) and Section
529A and amendment of Section 530(1), all sums due to any
employee from a provident fund, a pension fund, a gratuity fund C
 or any other fund established for welfare of the employees were
payable in priority to all other debts in a winding up
proceedings [Section 530(1)(f)). Even the wages, salary and
 other dues payable to the workers and employees were
payable in priority to all other debts. What Parliament has done D
by these amendments is to define the term ''workmen's dues"
and to place them at par with debts due to secured creditors
to the extent such debts rank under clause (c) of the proviso to
Section 529(1 ). However, these amendments, though
subsequent in point of time, cannot be interpreted in a manner E
which would result in diluting the mandate of Section 11 of the
EPF Act, sub-section (2) whereof declares that the amount due
from an employer shall be the first charge on the assets of the
establishment and shall be paid in priority to all other debts.
The words "all other debts" used in Section 11 (2) would F
necessarily include the debts due to secured creditors like
banks, financial institutions etc. The mere ranking of the dues
of workers at par with debts due to secured creditors cannot
lead to an inference that Parliament intended to create first
charge in favour of the secured creditors and give priority to G
the debts due to secured creditors over the amount due from
the employer under the EPF Act.

    43. At the cost of repetition, we would emphasize that in
terms of Section 530(1), all revenues, taxes, cesses and rates
due from the company to the Central or State Government or       H
    384    SUPREME COURT REPORTS [2011) 15 (ADDL.) S.C.R.


A    to a local authority, all wages or salary or any employee, in
     respect of the services rendered to the company and due for
     a period not exceeding 4 months all accrued holiday
     remuneration etc. and all sums due to any employee from
    provident fund, a pension fund, a gratuity fund or any other fund
B   for the welfare of the employees maintained by the company
    are payable in priority to all other debts. This provision existed
    when Section 11 (2) was inserted in the EPF Act by Act No.
    40 of 1973 and any amount due from an employer in respect
    of the employees' contribution was declared first charge on the
c   assets of the establishment and became payable in priority to
    all other debts. However, while inserting Section 529A in the
    Companies Act by Act No.35of1985 Parliament, in its wisdom,
    did not declare the workmen's dues (this expression includes
    various dues including provident fund) as first charge. The
    effect of the amendment made in the Companies Act in 1985
0
    is only to expand the scope of ~he dues of workmen and place
    them at par with the debts due to secured creditors and there
    is no reason to interpret this amendment as giving priority to
    the debts due to secured creditor over the dues of provident
    fund payable by an employer. Of course, after the amount due
E   from an employer under the EPF Act is paid, the other dues of
    the workers will be treated at par with the debts due to secured
    creditors and payment thereof will be regulated by the
    provisions contained in Section 529(1) read with Section
    529(3), 529A and 530 of the Companies Act.
F
       44. In view of what we have observed above on the
  interpretation of Section 11 of the EPF Act and Sections 529,
  529A and 530 of the Companies Act, the judgment of the
  Division Bench of the Gujarat High Court, which turned on the
G interpretation of Section 94 of the Employees' State Insurance
  Act and Sections 529A and 530 of the Companies Act and on
  which reliance has been placed by the learned Company Judge
  and the Division Bench of the High Court while dismissing the
  applications filed by the appellant, cannot be treated as laying
H down the correct law.
 EMPLOYEES PROVIDENT FUND COMMNR. v. O.L. OF 385
  ESSKAY PHARMACEUTICALS LTD. [G.S. SINGHVI, J.]

      45. In the result, the appeals are allowed. The impugned      A
judgment as also the order of the learned Company Judge are
set aside and the applications filed by the appellant are allowed
in terms of the prayer made. The Official Liquidator appointed
by the High Court shall deposit the dues of provident fund
payable by the employer within a period of 3 months. The            B
parties are left to bear their own costs.

D.G.                                          Appeals allowed.


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