SUNBEAM WOMEN'S COLLEGE V. UNION OF INDIA WRIT - C NO. 37031 OF 2025:

DATE: 03/02/2026

COURT: High Court of Allahabad

BENCH: Justice Swarupama Chaturvedi and Justice Ajit Kumar

FACTS:

The petitioner, Sunbeam Woman’s College, filed a writ petition before the High Court of Judicature at Allahabad challenging an order passed by the concerned respondent Commission directing reinstatement of respondent no. 5 and extending to her the benefits of the Maternity Benefit Act, 1961. The petitioner institution contended that the Act would not apply to an educational institution unless the State Government had issued a notification in the Official Gazette under the proviso to Section 2(1) of the Act, with the approval of the Central Government. According to the petitioner, no such notification had been issued by the State of Uttar Pradesh, and therefore, the Commission had exceeded its authority in granting relief under the Act.

In support of its contention, the petitioner relied upon a judgment of the Kerala High Court in Chairman, PSM College of Dental Science & Research Bye Pass Road v. Reshma Vinod and Others (2024), which held that educational institutions do not fall within the definition of “establishment” under the Shops and Establishments Act and, therefore, may not automatically attract the provisions of the Maternity Benefit Act. During the hearing, the High Court permitted impleadment of the State of Uttar Pradesh through the Additional Chief Secretary, Secondary Education, as a necessary party, observing that the State’s role in notifying and implementing the Act required examination.

ISSUES:

The principal issue before the Court is whether the Maternity Benefit Act, 1961, as amended in 2017, is applicable to the petitioner educational institution in the absence of a specific notification by the State Government under Section 2(1) of the Act. Additionally, the Court must consider whether the respondent Commission acted beyond its jurisdiction in directing reinstatement of respondent no. 5 and granting her maternity benefits without such notification.

JUDGEMENT WITH REASONING:

The High Court did not render a final decision on the merits but held that the matter required detailed consideration. It directed the State Government to file an affidavit explaining what steps, if any, had been taken to implement the Maternity Benefit Act, 1961 as amended in 2017. The Court ordered all respondents to file counter affidavits within four weeks, with rejoinder, if any, to follow within two weeks. It further directed that status quo regarding the employment of respondent no. 5 be maintained until further orders and listed the matter for final disposal on March 23, 2026.

The Court observed that the State had become a necessary party to the proceedings because the applicability of the Maternity Benefit Act to the petitioner institution hinged upon whether the State Government had discharged its statutory obligation to notify the Act for particular establishments. Since the petitioner’s primary argument was that no such notification had been issued, the Court found it essential to ascertain the State’s position before adjudicating upon the legality of the Commission’s order. Without clarity on whether the Act had been duly extended to cover such institutions, the Court considered it premature to determine the correctness of the reinstatement and grant of benefits.

Further, the Court recognized that the issue raised involved interpretation of a beneficial social welfare legislation and its applicability to educational institutions, an area that has seen judicial divergence. The petitioner’s reliance on the Kerala High Court judgment and Supreme Court precedent concerning the definition of “establishment” underscored the complexity of the matter. Given these legal and factual questions, the Bench deemed it appropriate to seek comprehensive pleadings from all parties and ensure the presence of the State to clarify its statutory role. At the same time, to balance equities and prevent prejudice pending adjudication, the Court ordered maintenance of status quo regarding the employment of respondent no. 5 and made it clear that the case would be finally decided on the next date without unnecessary adjournments.

ANALYSIS:

This case raises an important question regarding the scope and applicability of the Maternity Benefit Act, 1961 to educational institutions, particularly in the absence of a specific notification by the State Government under Section 2(1) of the Act. The petitioner’s argument hinges on a technical but significant statutory requirement, that the Act does not automatically extend to all establishments and must be formally notified by the State with the approval of the Central Government. By relying on judicial precedent interpreting the term “establishment” under analogous Shops and Establishments legislation, the petitioner seeks to limit the reach of the Act. At the same time, the underlying context involves a beneficial social welfare statute designed to secure maternity rights for working women. The tension in this case lies between a strict, text-based interpretation of statutory applicability and a purposive approach that advances the protective object of the legislation.

The High Court’s interim approach reflects judicial caution and procedural fairness. Rather than immediately endorsing or rejecting the petitioner’s statutory interpretation, the Court recognized that the State’s role in notifying and implementing the Act is central to resolving the dispute. By directing the State to clarify its position through an affidavit and maintaining status quo in the meantime, the Court balanced competing interests, protecting the employee from immediate prejudice while safeguarding the institution’s right to contest the legal basis of the Commission’s order. The case also highlights a broader systemic issue: whether beneficial labour protections can be effectively enforced when their applicability depends on executive notification. The final adjudication is likely to have implications not only for the parties involved but also for the application of maternity benefits to employees of private educational institutions across the State.