Employee inspection rights under company law do not extend to ex-employees after termination of service.

The right of inspection under section 419 of the Indian Companies Act, 1956 applies only to an existing employee, because the statutory language was found clear and the ordinary meaning of "employee" requires a continuing contract of service and master-servant relationship. Sections 417 and 418 did not indicate any legislative intent to extend that right to a former employee, and broader interpretations adopted under other statutes were distinguished as context-specific. As a result, an ex-employee cannot claim inspection of the bank's receipts and securities relating to the provident fund after termination of service.

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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, so as to entitle him to inspect the Bank's receipts and securities relating to the provident fund.

Analysis: Section 419 confers the right of inspection on an "employee" and section 420 creates the penalty for contravention of sections 417 to 419. The statutory language was found to be clear and unambiguous, and the ordinary meaning of "employee" was held to require an existing contract of service and a continuing master-servant relationship. The context of sections 417 and 418 did not disclose any indication that the Legislature intended to extend the right to an ex-employee. Authorities on broader constructions in other statutes were distinguished because they turned on different definitions and statutory settings.

Conclusion: The word "employee" in section 419 does not include an ex-employee or past employee. The complainant had no statutory right of inspection after termination of service, and the appeal failed.

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