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Issues: Whether the word "employee" in Section 419 of the Indian Companies Act, 1956 includes a past employee whose contract of service has been terminated, and whether such a person can claim inspection of the bank receipts and securities relating to the provident fund.
Analysis: Section 419 confers the right of inspection on an "employee" and Section 420 merely provides the penalty for contravention. The language of Section 419 was held to be plain and unambiguous. In the absence of any definition or internal indication in the Act suggesting that "employee" includes an ex-employee or past employee, the word was given its normal meaning, namely, a person presently in service under a relationship of master and servant. The Court distinguished the English decision relied upon, holding that it turned on the special definitions in that statute and could not control the construction of the Indian Companies Act. The wider object of the legislation could not be invoked to enlarge clear statutory language.
Conclusion: The word "employee" in Section 419 does not include a past employee or ex-employee, and the complainant had no statutory right of inspection after termination of service.
Final Conclusion: The prosecution based on breach of Section 419 could not succeed, and the State's appeal against acquittal failed.
Ratio Decidendi: Where the language of a penal or regulatory provision is clear, the court must give the statutory word its ordinary meaning and cannot extend it by reference to the supposed object of the enactment in the absence of any contextual indication to do so.