Case Synopsis

M/s. Carborandum Universal Ltd. vs. ESI Corporation

Citation: 2025 INSC 1455

Synopsis: The Supreme Court quashed a demand for ESI contributions raised against an employer for the period 1988-1992. The Court held that the ESI Corporation wrongly invoked its summary power under Section 45A of the ESI Act. This provision can only be used when an employer completely fails to produce/maintain records or obstructs inspection. Since the employer had produced records and participated in hearings, the Corporation's grievance about inadequate documentation did not justify a Section 45A order. The Court ruled that using this provision in such a scenario, especially after a long delay, was an attempt to circumvent the five-year limitation period applicable to normal recovery proceedings before the Employees Insurance Court under Section 75, and was therefore arbitrary and without jurisdiction.

1. Heading of the Judgment
M/s. Carborandum Universal Ltd. vs. ESI Corporation
Citation: 2025 INSC 1455 (Supreme Court of India)
Judges: Hon'ble Mr. Justice Manoj Misra & Hon'ble Mr. Justice Ujjal Bhuyan
Date: December 18, 2025

2. Related Laws and Sections
This judgment provides a definitive interpretation of the following key provisions of the Employees' State Insurance Act, 1948:

• Section 45A: Determination of contributions in certain cases.

• Section 45B: Mode of recovery of contributions.

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