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Issues: Whether compensation payable to workmen for lay-off under the Industrial Disputes Act, 1947 is "wages" within the meaning of the Payment of Wages Act.
Analysis: Lay-off compensation is a statutory payment made because the employer fails, refuses, or is unable to provide work, and the statutory scheme itself distinguishes such compensation from wages. The definition of wages requires a payment to be remuneration payable if the terms of employment are fulfilled and in respect of employment or work done. Compensation for lay-off is not paid for services rendered, but to mitigate the hardship of temporary unemployment. During lay-off, no work is done, the payment is not attributable to work done or employment in the relevant sense, and the statutory provisions do not convert it into remuneration. The additional clauses of the definition were also held inapplicable.
Conclusion: Lay-off compensation is not wages within the meaning of the Payment of Wages Act.