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Issues: Whether wages fixed by an industrial award fell within the definition of "wages" under section 2(vi) of the Payment of Wages Act, 1936 before the 1958 amendment.
Analysis: The unamended definition covered remuneration payable if the terms of the contract of employment, express or implied, were fulfilled. Industrial adjudication is not confined to existing contractual terms and may revise them in the interests of social justice. When an award prescribes a new wage structure, the contractual wage structure becomes inoperative and is supplanted by the wage structure fixed by the award. In substance and in law, the award operates as a fresh contractual arrangement between employer and workmen. The later amendment was treated as clarificatory of what was already included in the earlier definition.
Conclusion: Wages fixed by an industrial award were included within section 2(vi) even before the 1958 amendment, so the claim under section 15 was maintainable.
Ratio Decidendi: Where industrial adjudication lawfully supplants contractual wage terms by an award, the remuneration fixed by that award is remuneration payable under the employment relationship and falls within the unamended statutory definition of wages.