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Issues: Whether casual employees engaged on a temporary or intermittent basis fall within the expression "employee" under the Employees' State Insurance Act, 1948.
Analysis: The definition of "employee" in Section 2(9) is broad enough on a literal reading to include such workers, but the wider statutory scheme was treated as controlling. Sections 38 and 39(1) show that insurance and contribution are linked to the benefits provided by the Act, while Section 47 indicates that sickness benefit depends upon the existence of a qualifying contribution period. Reading the provisions together, the Court held that the Act contemplates regular coverage where contributions have a practical relation to benefits and does not fit a casual engagement of a day or a few days. The Court also noted that if casual workers were intended to be covered, the Act would have said so expressly.
Conclusion: Casual employees are not within the purview of the Act.
Ratio Decidendi: A statutory definition, even if wide in terms, must yield to the scheme and purpose of the enactment where the contribution structure and benefit entitlement show that coverage is intended for employees whose service bears a practical relation to the statutory insurance benefits.