Bank and Pygmy Agents – Application of EPF Act –

The expression “in or in connection with the work” in section 2(f) of the EPF Act, there must be some nexus, however, loose, between the establishment and its work.  The conceptual contract has the essence of the offer of work, acceptance of each other where the employee or such person agrees to produce the result under consideration for service in form of wages or cash.   There is control of the bank over the work of pygmy agent.   The learned Commissioner also considered master servant relationship has been held when the person so engaged with work of a Banking institution has commercial and financial significance in the Bank’s regular course of business activity and is doing the work for monetary payment the work done is necessary to main operation of the establishment being a banking institution.

Judgment dated 13.2.2025 of the High Court of Bombay, Bench at Nagpur, in  Writ Petition No.2039 of 2024 of M/s. Wardha Nagri Sahakari Adhikoshi Maryadit Bank  Vs  Employees Provident Fund