N. Manoharan vs The Adminsitrative Officer

insc-2026-143 Supreme Court of India 11 February 2026 • SPECIAL LEAVE PETITION (CIVIL) NO. 22670 OF 2024 • 13 min read

4 cases cited (0 SG, 4 foreign) Cited by 1 case

Practice Areas

AE Act Atomic Energy Act, 1962 Companies Act, 2013 Industrial Disputes Act, 1947 PG Act PG Act depend on the Act PG Act, 1972 Payment of Gratuity Act, 1972

Judges (2)

Pankaj Mithal Coram S.V.N. Bhatti Delivered

Parties (2)

Administrative Officer Respondent N. Manoharan Appellant

Case Significance

N. Manoharan vs The Adminsitrative Officer is a Supreme Court of India decision dated February 11, 2026 (citation: insc-2026-143). Retired employees of Heavy Water Plant, Department of Atomic Energy sought coverage under the Payment of Gratuity Act, 1972. The Supreme Court dismissed the appeals, holding that HWP employees fall within the exclusionary clause as HWP is an adjunct of the Department of Atomic Energy. The bench comprised Justices Pankaj Mithal and S.V.N. Bhatti. The judgment was delivered by Justice S.V.N. Bhatti.

This case has been cited by 1 subsequent judgment. The judgment references 4 case citations.

Summary

Retired employees of Heavy Water Plant, Department of Atomic Energy sought coverage under the Payment of Gratuity Act, 1972. The Supreme Court dismissed the appeals, holding that HWP employees fall within the exclusionary clause as HWP is an adjunct of the Department of Atomic Energy.