[Analysis] Pending Proceedings and Transition under Code on Social Security 2020 – Section 153 | Section 164 | Deadlines
- Blog|Advisory|Labour & Industrial Laws|
- 17 Min Read
- By Taxmann
- |
- Last Updated on 3 September, 2026

Pending proceedings under the Code on Social Security 2020 are governed by section 153, section 164(2), the third proviso to section 125(2), and section 6 of the General Clauses Act, 1897 as applied by section 164(3). Section 153 keeps the old boards and corporations functioning as their Code counterparts until replacements are constituted or their terms expire. Section 164(2)(a) deems what was done under the repealed Acts to have been done under the Code. Six transitional deadlines are running, the first on 31 October 2026 and the last on 21 November 2027.
Law stated as on 1 September 2026. The Code on Social Security, 2020 was brought into force in stages, the bulk of it with effect from 21 November 2025.
Table of Contents
- The question this answers
- Section 153: the institutions carry on
- What was done stays done
- The one-year clock on the old schemes
- Exemptions granted under a repealed Act
- Inquiries that were already running
- Section 6 of the General Clauses Act
- What the courts have said so far
- The transitional dates
- Frequently asked questions
- Conclusion
1. The question this answers
On 21 November 2025 eight of the nine repealed Acts stopped and one Code started. The ninth, the Employees’ Provident Funds and Miscellaneous Provisions Act, 1952, had begun to go two and a half years earlier: S.O. 2060(E), dated 3 May 2023, brought section 164(1) into force so far as it repealed the corresponding provisions of that Act specified in item 3. Almost nothing else stopped. Part-heard inquiries were part-heard, exemptions were running, boards were mid-term, and schemes made under the repealed Acts were still the instruments people worked from.
Our note on the nine Acts subsumed in the Code covers the mapping of old law to new. This note is about the narrower and more urgent question: what happened to the things that were already in motion, and by when does each of them have to be resolved.
Three provisions of the Code on Social Security, 2020 answer it, and they do different jobs. Section 153 carries the institutions across. Section 164(2) carries the acts and instruments across. Section 6 of the General Clauses Act, 1897, applied by section 164(3), carries the rights, liabilities and proceedings across. The hardest deadline is elsewhere again, in the third proviso to section 125(2), and the most useful relief is not in the Code at all but in the Annexure to the Employees’ Provident Funds Scheme, 2026. The Ministry of Labour and Employment’s Compliance Handbook for Employers under the Four Labour Codes covers the parallel transition under the other three codes.
2. Section 153: the institutions carry on
Section 153 has no counterpart in any of the repealed Acts, as the corresponding-provisions note against it records. That is as it should be: a consolidating statute needs a bridge the statutes it consolidates never had to build.
The section names six bodies constituted or established under the repealed enactments and provides that, after commencement, each shall continue to exercise the powers and discharge the functions of the corresponding organisation under the Code:
| Body under the repealed Act | Continues as, under the Code |
| Central Board, section 5A, EPF Act, 1952 | Central Board of Trustees for Employees Provident Fund, section 4 |
| Executive Committee, section 5AA, EPF Act, 1952 | Executive Committee, section 4(3) |
| The Corporation, section 3, ESI Act, 1948 | Employees State Insurance Corporation, section 5 |
| Medical Benefit Council, section 10, ESI Act, 1948 | Medical Benefit Committee, section 5(5) |
| Standing Committee, section 8, ESI Act, 1948 | Standing Committee, section 5(3) |
| The Board, section 18(1), Building and Other Construction Workers (Regulation of Employment and Conditions of Service) Act, 1996 | Building Workers’ Welfare Board, section 7(1) |
Each is treated as if it had been constituted under the respective provisions of the Code. The bridge is not permanent. It lasts until the corresponding organisation is constituted under the Code, or until the body’s own time period under the repealed enactment expires, whichever is earlier.
The sixth entry repays attention. The Building and Other Construction Workers (Regulation of Employment and Conditions of Service) Act, 1996 is not one of the nine Acts repealed by section 164(1); only the companion Cess Act of the same year was. Section 153 nevertheless reaches a board constituted under it, and there is a drafting oddity in the way it does so: the opening words describe all six as “organisations constituted or established under the enactments repealed under section 164”, and the sixth was not. The Code took the cess and left the regulation Act standing, but it took the board with the cess, and sections 106 and 107 of the Code took that Act’s provisions on registration of building workers as beneficiaries and on cessation with it. Our note on the BOCW cess under the Code works through what Chapter VIII carries.
3. What was done stays done
Section 164(2)(a) is the widest of the savings and the one most often relied on without being read.
Anything done or any action taken under the repealed enactments, including any rule, regulation, notification (expressly including notifications issued by the States), scheme, appointment, order or direction made under them, or any benefit provided or given under them, is deemed to have been done or taken under the corresponding provisions of the Code.
Two conditions ride on that deeming, and they are what make it less than absolute:
- it holds only to the extent those things are not contrary to the Code, including any rule, regulation, notification, scheme, appointment, order or direction made under the Code; and
- it holds only until they are repealed under the corresponding provisions of the Code by the appropriate Government.
The practical reading is that an old instrument survives on sufferance. It is good until something in the Code contradicts it, and good until the Government replaces it. Neither event needs a saving to be withdrawn; each simply displaces the instrument. An adviser asked whether a State notification from 2019 still binds is therefore asking two questions, not one: does anything in the Code or its subordinate legislation contradict it, and has the appropriate Government replaced it.
4. The one-year clock on the old schemes
Section 164(2)(b) is the only clause of section 164 with a date attached, and it is a short one.
Four named instruments made under the EPF Act, 1952, together with the rules, regulations and schemes made under the ESI Act, 1948, remain in force to the extent they are not inconsistent with the Code, for one year from the date of commencement of the Code:
- the Employees’ Provident Funds Scheme, 1952;
- the Employees’ Deposit Linked Insurance Scheme, 1976;
- the Employees’ Pension Scheme, 1995; and
- the Tribunal (Procedure) Rules, 1997.
Clause (b) did not commence on one date, and that changes the answer for one of the four instruments. Insofar as it relates to the Employees’ Pension Scheme, 1995, clause (b) was brought into force on 3 May 2023 by S.O. 2060(E), item (vii). Section 1(3) of the Code then decides what “commencement” means for it: different dates may be appointed for different provisions, and “any reference in any such provision to the commencement of this Code shall be construed as a reference to the coming into force of that provision”. The one-year saving for the Pension Scheme, 1995 therefore ran from 3 May 2023 and expired in May 2024.
The rest of section 164(2) and the whole of section 164(3) came into force on 21 November 2025 under S.O. 5319(E), whose entry at serial number 8 was recast by Corrigendum S.O. 5936(E), dated 19 December 2025, to read “sub-sections (2) and (3) of section 164 except the provisions of the Code specified at serial number (vii) of S.O. 2060(E), dated the 3rd May, 2023”. So for the Employees’ Provident Funds Scheme, 1952, the Employees’ Deposit Linked Insurance Scheme, 1976, the Tribunal (Procedure) Rules, 1997 and the ESI Act’s rules, regulations and schemes, the year runs from 21 November 2025.
Section 9 of the General Clauses Act, 1897 excludes the first day where a period runs “from” a date, so that year expires at the end of 21 November 2026.
Most of that ground has since been taken by replacement. The Social Security (Central) Rules, 2026, notified on 8 May 2026 by G.S.R. 344(E), superseded twelve sets of rules, including the Employees’ State Insurance (Central) Rules, 1950, the Tribunal (Procedure) Rules, 1997 and the Employees’ Provident Funds Appellate Tribunal (Conditions of Service) Rules, 1997. The Employees’ Provident Funds Scheme, 2026, the Employees’ Pension Scheme, 2026 and the Employees’ Deposit-Linked Insurance Scheme, 2026 were notified on 29 June 2026 by G.S.R. 525(E), 527(E) and 526(E). The Pension Scheme, 2026 supersedes two schemes rather than one: it is expressed to be in supersession of the Employees’ Family Pension Scheme, 1971 as well as the Employees’ Pension Scheme, 1995.
What is left is the residue, and it is worth identifying rather than assuming away. Regulations made by the Employees’ State Insurance Corporation under the 1948 Act are not rules made by the Central Government, and were not swept up by the 2026 Rules. Clause (b)’s one-year saving for them lapses in November 2026 — but it is worth being careful about what that lapse does, because clause (a) saves the same regulations independently and without any date, until they are contrary to the Code or the appropriate Government repeals them. What runs out in November is the belt, not the braces. Even so, a process still resting on an ESI regulation is better traced before that date than after it, because after it the argument has to be made on clause (a) alone.
5. Exemptions granted under a repealed Act
Section 164(2)(c) treats exemptions separately from everything else, and more generously. Any exemption given under a repealed enactment continues to be in force until one of three things happens:
- its validity expires;
- it ceases to be in operation under the provisions of the Code; or
- a direction is made under the Code for that purpose.
An establishment exempted under section 17 of the EPF Act, 1952 does not need to re-apply on day one. But the clause is a survival provision, not a renewal provision: when the exemption’s own validity period runs out, it runs out, and the fresh grant is then governed by section 143 of the Code. Section 143(3) makes the initial period three years from the date of publication of the notification, and the proviso to section 143(1) bars a grant or renewal without prior consultation — with the Central Board in respect of the Provident Fund, Pension and Insurance Schemes, and with the Corporation in respect of Chapter IV.
The conditions for that fresh grant are in rule 65 of the Social Security (Central) Rules, 2026, and they are demanding. The establishment must have complied with Chapter III or Chapter IV, or with the corresponding repealed Act, for a continuous period of three years immediately before the application, without default in payment of contribution. It must have at least five hundred contributory members or employees on the date of application. Where exemption is sought from the Provident Fund Scheme or the Pension Scheme, it must have a cumulative balance in members’ accounts of fifty crore rupees or more. It must have a positive net worth in each of the last three years, furnish the consent of a majority of employees for Chapter III, seed Aadhaar for every member, and provide online claim settlement and a grievance portal linked to the Employees’ Provident Fund Organisation within ninety days of the grant. Rule 65(2) then provides that the notification takes effect from the date of the notification, so nothing is regularised backwards.
Nothing, that is, except through AMNESTY, 2026. Part C of the Annexure to the Employees’ Provident Funds Scheme, 2026 exists to solve exactly the problem rule 65 creates for a trust that has been operating without a formal notification of exemption. Exempted establishments which apply are granted amnesty retrospectively under section 17 of the repealed Act read with paragraphs 27 and 27A of the 1952 Scheme and section 143 of the Code; the period for which the trust has been operating is deemed to satisfy the three-year compliance requirement; and the minimum requirement for the number of employees and the corpus is waived. Proceedings pending for assessment of dues or damages are to be withdrawn and stand abated, and completed orders are to be held void ab initio, with any amount recovered adjusted against future dues and subject to appeal under section 23. AMNESTY, 2026 remains valid for six months from the notification of the Scheme on 29 June 2026, extendable by up to six months on the recommendations of the Central Board.
6. Inquiries that were already running
The most concrete transitional deadline is not in section 164 at all. It is the third proviso to section 125(2).
Inquiries pending immediately before the date of commencement of the Code shall be concluded by the Authorised Officer within a period not exceeding two years from the date of such commencement. Two years from 21 November 2025, excluding the first day under section 9 of the General Clauses Act, 1897, expires at the end of 21 November 2027.
That is a different obligation from the general one in section 125(2), which requires only that endeavour be made to conclude the inquiry within two years and fixes no starting point at all, with an extension of up to one year available from the Central Provident Fund Commissioner or the Director General on the circumstances and reasons recorded by the Authorised Officer and submitted to him. The third proviso fixes a single outer date for the whole legacy stock, and the extension machinery in the second proviso is not written to apply to it.
Nor does the five-year bar in the proviso to section 125(1) help an employer whose inquiry was already on foot. That proviso bars initiation after five years; it says nothing about an inquiry initiated before commencement under section 7A or section 45A. The detail of how assessment now works is in our note on assessment, recovery and compliance under the Code.
There is, however, a live route through a pending inquiry, and it closes before any of the other deadlines. Part A of the Annexure to the Employees’ Provident Funds Scheme, 2026 constitutes the Employees’ Enrolment Campaign, 2026, which came into force on the publication of that Scheme and ceases to operate on 31 October 2026. Paragraph (10) makes every establishment eligible irrespective of the fact whether any establishment is facing inquiries under section 125 of the Code, section 7A of the repealed Act, paragraph 11 of the 2026 Scheme, paragraph 26-B of the 1952 Scheme, or paragraph 8 of either Pension Scheme. Paragraph (11) then requires the inquiry officer to take the declaration made under the Campaign into consideration while deciding the matter.
Paragraph (4) is the qualification that decides how much any of this is worth, and it is the one that matters most. Where any of those inquiries is pending and the employer opts for the Campaign, both the employee and the employer contribution shall be payable as per the provisions of the Code and the Schemes made thereunder. Paragraph (12) then confines the benefit, where the declaration pertains to the stipulated period of inquiry, to limiting the damages to the notional damages provided for under the Campaign in respect of the employees, their wages or amount of contributions and the duration of their employment so declared. For an establishment already under inquiry, in other words, the Campaign buys the damages concession and not the contribution concession.
Outside a pending inquiry the terms are unusually favourable. For employees who joined between 1 April 2009 and 31 March 2026 and were never enrolled, the member’s contribution stands waived under paragraphs (13)(b) and (17) where it was not deducted earlier and has not since been recovered, so the employer pays only his own share. Damages are levied at a flat one hundred rupees for the whole period of default, though the damages Table runs from 1 July 2009, three months after the enrolment window opens on 1 April 2009. Interest under section 127 and administrative charges remain payable. A declaration made by misrepresentation or suppression of facts is void ab initio.
7. Section 6 of the General Clauses Act
Section 164(3) provides that, without prejudice to sub-section (2), section 6 of the General Clauses Act, 1897 applies to the repeal. That section is the default rule for what a repeal does not disturb. Unless a different intention appears, a repeal shall not:
- revive anything not in force or existing when the repeal takes effect;
- affect the previous operation of the repealed enactment or anything duly done or suffered under it;
- affect any right, privilege, obligation or liability acquired, accrued or incurred under it;
- affect any penalty, forfeiture or punishment incurred for an offence against it; or
- affect any investigation, legal proceeding or remedy in respect of any such right, privilege, obligation, liability, penalty, forfeiture or punishment,
and any such investigation, legal proceeding or remedy may be instituted, continued or enforced, and any such penalty, forfeiture or punishment may be imposed, as if the repealing Act or Regulation had not been passed.
The point that decides most transitional arguments is the one settled in T.S. Baliah: section 6 applies even where the repeal is followed by simultaneous re-enactment, unless a contrary intention can be gathered from the new statute. The question is not whether the new Act expressly keeps old rights alive but whether it manifests an intention to destroy them, and the mere absence of a saving clause is by itself not material.[1] Gajraj Singh states the same rule.[2]
Two limits are worth carrying alongside it. Section 6 saves an accrued right; it does not create one. Where a new Act confers a right it does so prospectively from commencement, unless it says otherwise.[3] And where a provision is simply omitted and replaced without a saving for pending proceedings, the inference is that pending proceedings do not continue, though fresh proceedings may be begun under the new provision.[4]
8. What the courts have said so far
A first line of authority on continuity under the labour codes appeared in 2026. Only one of the five below is a Social Security Code case; the rest arise across the other codes and are being answered on general repeal principles, which is why they are worth reading together. They do not all point the same way.
- The savings clause under the Code on Wages, 2019 protects actions taken under the old law.[5]
- A new welfare cess scheme may be framed under the Code on Social Security, 2020.[6]
- Authorities under the Industrial Disputes Act continue to function until authorities are appointed under the Industrial Relations Code.[7]
- A reference order made before the retrospective repeal of the Industrial Disputes Act remains valid.[8]
- On a different view, the Industrial Disputes Act and the Standing Orders Act have not been repealed yet.[9]
The third of those is the closest analogue to section 153, and it runs with it: institutional continuity until replacement, not a gap.
9. The transitional dates
Six transitional deadlines are now running, and they are not connected to each other.
| Date | What happens | Source |
| 31 October 2026 | The Employees’ Enrolment Campaign, 2026 ceases to operate | Part A(1) of the Annexure to the Employees’ Provident Funds Scheme, 2026 |
| 21 November 2026 | The one-year saving lapses for the Employees’ Provident Funds Scheme, 1952, the Employees’ Deposit Linked Insurance Scheme, 1976, the Tribunal (Procedure) Rules, 1997 and the ESI Act’s rules, regulations and schemes, so far as they have not already been superseded. In practice what is left is the ESI Corporation’s regulations. For the Employees’ Pension Scheme, 1995 it expired in May 2024 | Section 164(2)(b), read with S.O. 2060(E) dated 3-5-2023, S.O. 5319(E) as corrected by S.O. 5936(E), and section 1(3) |
| End of December 2026 | VISHWAS, 2026 closes, unless extended by up to six months by the Central Provident Fund Commissioner for reasons recorded in writing | Part B(2) and B(3) of the same Annexure, six months from notification on 29 June 2026 |
| End of December 2026 | AMNESTY, 2026 closes, unless extended by up to six months on the recommendations of the Central Board | Part C(2) and C(3) of the same Annexure |
| 21 November 2027 | Every inquiry pending immediately before commencement must be concluded | Third proviso to section 125(2) |
| 21 November 2027 | No further order removing difficulties may be made | Proviso to section 163(1) |
Three of the six are settlement windows rather than lapses, and all three sit in the same Annexure to the Employees’ Provident Funds Scheme, 2026. The Enrolment Campaign deals with employees who were never enrolled, AMNESTY with exempted establishments whose trusts were never formally notified, and VISHWAS with damages.
VISHWAS, 2026 applies to damages for default in payment of contribution for the period prior to 14 June 2024, in four situations: where an order under section 14B of the repealed Act or section 128 of the Code has been issued and is under dispute before a judicial forum; where such an order has been issued and the amount is yet to be recovered; where a notice has been issued and the final order is yet to be issued; and where a notice is yet to be issued. It does not apply where the entire amount under section 14B or section 128 has already been deposited.
Where it does apply, an appeal filed, or an order passed under section 7-I of the repealed Act or before any judicial forum, against such a notice or order stands abated on the remittance of the recomputed damages. Two conditions ride on that abatement, and both are easy to miss. The interest under section 7Q of the repealed Act or section 127 of the Code for the corresponding period must be fully remitted or recovered. And the employer must submit an undertaking that no further appeal will be filed before any forum consequent on the abatement. A pre-deposit already made under section 7-O of the repealed Act or section 23(3) of the Code is treated as a valid deposit and set against the recomputed figure, with any excess adjusted against other orders or notices.
10. Frequently asked questions
What happens to a proceeding started under the EPF Act or the ESI Act?
It continues. Section 6 of the General Clauses Act, 1897, applied by section 164(3), preserves any investigation, legal proceeding or remedy in respect of a right, obligation, liability or penalty accrued under the repealed Act, and allows it to be instituted, continued or enforced as if the repealing Act had not been passed. For inquiries specifically, the third proviso to section 125(2) requires those pending immediately before commencement to be concluded within two years of it, that is by 21 November 2027.
Are the old EPF and ESI boards still valid?
Yes, for now. Section 153 provides that the Central Board and Executive Committee under the EPF Act, the Corporation, Medical Benefit Council and Standing Committee under the ESI Act, and the Board under section 18(1) of the Building and Other Construction Workers (Regulation of Employment and Conditions of Service) Act, 1996 continue to exercise the powers and discharge the functions of their Code counterparts, as if constituted under the respective provisions of the Code, until the corresponding organisations are constituted under the Code or their respective time periods under the repealed enactments expire, whichever is earlier.
Do notifications issued under the repealed Acts still apply?
Section 164(2)(a) deems anything done under a repealed enactment, including any rule, regulation, notification, scheme, appointment, order or direction, and expressly including State notifications, to have been done under the corresponding provision of the Code. It holds only so far as the instrument is not contrary to the Code, and only until the appropriate Government repeals it under the corresponding provision.
Does an exemption granted under the old EPF Act still hold?
Yes. Under section 164(2)(c) an exemption given under a repealed enactment continues in force until its validity expires, or it ceases to operate under the Code, or a direction is made under the Code for that purpose. A fresh grant after that is governed by section 143 of the Code, which sets an initial period of three years from the date of publication of the notification and bars a grant or renewal without prior consultation with the Central Board in respect of the Provident Fund, Pension and Insurance Schemes and with the Corporation in respect of Chapter IV. The eligibility conditions are in rule 65 of the Social Security (Central) Rules, 2026, and AMNESTY, 2026 in the Annexure to the Employees’ Provident Funds Scheme, 2026 offers a retrospective route for exempted establishments whose trusts were never formally notified.
When does the one-year saving for the old schemes expire?
It depends on the scheme, because section 164(2)(b) did not commence on one date. Insofar as it relates to the Employees’ Pension Scheme, 1995, clause (b) came into force on 3 May 2023 under S.O. 2060(E), and section 1(3) of the Code makes a reference to the commencement of the Code in a provision a reference to the coming into force of that provision, so the one-year saving for that Scheme expired in May 2024. For the Employees’ Provident Funds Scheme, 1952, the Employees’ Deposit Linked Insurance Scheme, 1976, the Tribunal (Procedure) Rules, 1997 and the ESI Act’s rules, regulations and schemes, clause (b) came into force on 21 November 2025 under S.O. 5319(E) as corrected by S.O. 5936(E), so the year expires at the end of 21 November 2026. Most of those instruments have since been superseded by the Social Security (Central) Rules, 2026 and the 2026 schemes, and section 164(2)(a) saves the remainder independently and without a date.
What relief is available to an employer with a pending EPF inquiry?
The Annexure to the Employees’ Provident Funds Scheme, 2026 carries three special provisions. The Employees’ Enrolment Campaign, 2026 ceases to operate on 31 October 2026. Outside a pending inquiry it lets an employer declare employees who joined between 1 April 2009 and 31 March 2026 and were never enrolled, with the member’s contribution waived where it was not deducted earlier and damages levied at a flat one hundred rupees. Where an inquiry under section 125 of the Code or section 7A of the repealed Act is already pending, paragraph (10) still makes the establishment eligible and paragraph (11) requires the inquiry officer to take the declaration into consideration, but paragraph (4) makes both the employee and the employer contribution payable, and paragraph (12) confines the benefit to limiting the damages to the notional damages under the Campaign. VISHWAS, 2026 settles damages for defaults for periods prior to 14 June 2024 and abates a pending appeal or an order under section 7-I on remittance of the recomputed damages, subject to full remittance of interest and an undertaking not to appeal further. AMNESTY, 2026 regularises exempted establishments retrospectively and abates pending assessment proceedings. VISHWAS and AMNESTY each run for six months from 29 June 2026, extendable by up to six months.
11. Conclusion
The transition was designed for continuity, and on the whole it delivers it. The boards kept sitting, the notifications kept binding, the exemptions kept running, and section 6 of the General Clauses Act kept the accrued rights and pending proceedings alive.
What the design does not do is remove the need to check. Every one of the savings is conditional: section 153 lasts until a replacement is constituted or a term expires; section 164(2)(a) lasts until the Code contradicts the instrument or the Government replaces it; section 164(2)(b) lasted a year, and that year has already ended for the Employees’ Pension Scheme, 1995 and ends in November 2026 for the rest; section 164(2)(c) lasts as long as the exemption’s own validity. A saving that is conditional in four different ways is not a reason to stop looking.
The part of the transition an employer can actually act on is not in the Code at all. It is the Annexure to the Employees’ Provident Funds Scheme, 2026, which carries three windows: the Employees’ Enrolment Campaign, 2026, closing on 31 October 2026; VISHWAS, 2026 for damages; and AMNESTY, 2026 for exempted establishments, the last two running six months from 29 June 2026. Each of them abates something that would otherwise have to be fought, and each of them has an expiry date in the next few months.
For section 153 and section 164 with the commentary on repeal, implied repeal, savings and section 6 of the General Clauses Act, and the 2026 decisions collected under it, see Taxmann’s Law & Practice Relating to Code on Social Security. Live notifications and case law are on Taxmann.com | Research.
[1] T.S. Baliah v. ITO, AIR 1969 SC 701.
[2] Gajraj Singh v. State, (1997) 1 SCC 650.
[3] State of Punjab v. Bhajan Kaur, (2008) 12 SCC 112 : (2009) 1 SCC (Cri) 328.
[4] Kolhapur Canesugar Works Ltd. v. Union of India, (2000) 2 SCC 536 : 2000 taxmann.com 1065.
[5] Tech Mahindra Ltd. v. Union of India, 2026 LLR 128 (Bom).
[6] Salem Mandala Manuneddhi Amaipuchara Mattrum Kattumana Thozhirchanga M v. Government of Tamil Nadu, 2026 LLR 130 (Mad).
[7] N.A. Sebastian v. Union of India, 2026 LLR 256 (Del).
[8] Glastronix LLP v. President/General Secretary, Glastronix Karmika Sangha, 2026 LLR 390 (Karn).
[9] United Labour of Federation v. Union of India and Anr., 2026 LLR 135 (Mad).
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