Accrued bonus rights and mandamus protection cannot be nullified by later law without compensation.

An accrued bonus entitlement recognised by a final writ of mandamus was not displaced merely because later legislation altered the underlying settlement; the statute neither referred to the judgment nor contained a non obstante clause directed to judicial orders, so the employees' enforceable rights under the mandamus remained intact. The Court also treated the crystallised bonus claim, once it became a debt due, as property. By extinguishing that accrued debt in substance for the benefit of a State-controlled corporation, the Act amounted to compulsory acquisition under Article 31(2). Because no compensation was provided, the legislation was invalid.

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Issues: (i) Whether the impugned legislation could extinguish the employees' crystallised entitlement to bonus despite the subsisting writ of mandamus and final judgment of the High Court. (ii) Whether the impugned legislation amounted to compulsory acquisition of property within Article 31(2) of the Constitution without provision for compensation.

Issue (i): Whether the impugned legislation could extinguish the employees' crystallised entitlement to bonus despite the subsisting writ of mandamus and final judgment of the High Court.

Analysis: The entitlement to bonus for the relevant year had been recognised by a final writ of mandamus in favour of the employees. A later statute which merely alters the settlement does not, by that fact alone, destroy a subsisting judicial command unless the statute clearly and effectively addresses the judgment itself. The judgment held that the impugned Act did not expressly refer to the High Court's mandate, did not contain a non obstante clause directed to judgments, and therefore did not absolve the employer from obedience to the writ already issued.

Conclusion: The Act did not nullify the binding effect of the High Court's mandamus, and the employees retained enforceable rights under that judgment.

Issue (ii): Whether the impugned legislation amounted to compulsory acquisition of property within Article 31(2) of the Constitution without provision for compensation.

Analysis: The right to receive bonus, when crystallised under the settlement and when it had accrued as a debt due from the employer, was held to be property. The Court treated debts and other transferable rights in personam as property capable of acquisition. By nullifying the settlement provisions with effect from an earlier date, the Act in substance extinguished the employees' accrued debts and transferred the economic benefit to the State-controlled corporation. The Court applied a substance-over-form approach and held that extinguishment of the debt, where the beneficiary was the State or a corporation controlled by it, amounted to compulsory acquisition within Article 31(2). Since the Act made no provision for compensation, it could not be sustained.

Conclusion: The impugned Act violated Article 31(2) and was void for want of compensation.

Final Conclusion: The legislation was struck down, and the employees' entitlement to bonus under the settlement and the mandamus remained enforceable.

Ratio Decidendi: A statute that, in substance, extinguishes accrued debts or transferable rights in personam in favour of a State-controlled corporation effects compulsory acquisition of property under Article 31(2) and is invalid if it provides no compensation.

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