Bonus recovery under execution-like proceedings fails where the award does not expressly grant bonus and entitlement remains disputed.

Bonus could not be recovered under Section 6-H(1) of the U.P. Industrial Disputes Act, 1947 as part of "wages" or as deferred wages under the award, because that provision functions like an execution mechanism and cannot be used to decide a disputed substantive entitlement. The award granted reinstatement and partial back wages and allowances, but did not expressly award bonus. Since bonus is excluded from the statutory definition of "wages" under the Act and from "salary or wage" under the Payment of Bonus Act, the Labour Commissioner could not enlarge the award or determine a fresh claim under Section 6-H(1). The recovery orders were therefore unsustainable.

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Issues: Whether bonus could be recovered under Section 6-H(1) of the U.P. Industrial Disputes Act, 1947 by treating it as part of "wages" or as deferred wages under the award, and whether such a claim was maintainable as an execution-type proceeding.

Analysis: Section 6-H(1) is in the nature of an execution provision and can be used only to compute and recover money already due under an award, not to decide a disputed substantive entitlement. The award granted reinstatement and 50% of back wages/allowances, but it did not expressly grant bonus. The statutory definition of "wages" under the U.P. Industrial Disputes Act, 1947 excludes bonus, and the corresponding definition in the Payment of Bonus Act, 1965 also excludes bonus from "salary or wage". The Labour Commissioner could not enlarge the scope of the award by treating bonus as deferred wages or by deciding a disputed claim that, if at all, had to be raised in the manner provided by the bonus legislation and industrial dispute machinery.

Conclusion: The claim for bonus under Section 6-H(1) was not maintainable, and the orders allowing such recovery were unsustainable.

Final Conclusion: The award and the statutory recovery mechanism could not be stretched to cover bonus, and the appellant was entitled to succeed.

Ratio Decidendi: A claim for bonus, when disputed and not expressly covered by the award, cannot be enforced through an execution-like proceeding under Section 6-H(1) of the U.P. Industrial Disputes Act, 1947, because bonus is excluded from "wages" and the authority under that provision cannot adjudicate a fresh substantive entitlement.

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