Minimum bonus obligation upheld as a reasonable restriction in public interest, despite employer hardship and constitutional challenge.

Section 10 of the Bonus Act was upheld as a reasonable restriction in public interest, even though it required payment of the statutory minimum bonus in years of loss. The constitutional challenge under Articles 19(1)(g) and 301 failed because the Court treated the obligation as consistent with constitutional policy, with the Directive Principles informing the reasonableness of the legislative measure rather than rendering it an impermissible burden on business or trade.

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Issues: Whether section 10 of the Bonus Act is unconstitutional as infringing the employer's freedom to carry on business and freedom of trade under Articles 19(1)(g) and 301 of the Constitution of India.

Analysis: The provision requiring payment of the statutory minimum bonus even in years of loss was held to be a reasonable restriction and one in public interest. The constitutional challenge was rejected on the footing that the Directive Principles of State Policy inform the reasonableness of such legislative measures, and payment of bonus was treated as an implementation of constitutional policy rather than an impermissible burden on business or trade.

Conclusion: Section 10 of the Bonus Act was upheld as constitutionally valid and the challenge under Articles 19(1)(g) and 301 failed.

Ratio Decidendi: A statutory obligation to pay minimum bonus may be upheld as a reasonable restriction in public interest where it advances the constitutional policy embodied in the Directive Principles.

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