Bihar State Ardh Sarkari Arajpati Karamchari Maha Sangh and Othersv.State of Bihar and Others

Legal Analysis: Bihar State Ardh Sarkari Arajpati Karamchari Maha Sangh and Others v. State of Bihar and Others

Citation: 2026 INSC 607

Court: Supreme Court of India

Bench: A Division Bench comprising Justice Sandeep Mehta & Justice Vikram Nath

Date of Decision: May 29, 2026

Nature of Judgment: Writ Petition (Civil) No. 932 of 2022 – proceedings concerning non‑payment of salaries, retiral dues and other emoluments to employees of five State‑owned Corporations following the bifurcation of the erstwhile State of Bihar under the Bihar Reorganisation Act, 2000.

Synopsis of the Judgment

The writ petition was filed by an association of employees of five State‑owned Corporations (Bihar State Construction Corporation Ltd., Bihar State Industrial Development Corporation Ltd., Bihar State Electronic Development Corporation Ltd., Bihar State Forest Development Corporation Ltd., and Bihar State Panchayati Raj Financial Corporation Ltd.). Following the creation of Jharkhand in 2000, the assets and liabilities of these Corporations were required to be apportioned between Bihar and Jharkhand, but the process remained unresolved for nearly two and a half decades, causing acute financial distress, destitution, and reported instances of suicides and starvation deaths among affected employees and their families. The Supreme Court constituted a Committee under the Chairmanship of Hon'ble Mr. Justice Dinesh Maheshwari (Retd.) to examine the issues. The Committee submitted a final report covering fixation of liabilities, identification of employees, determination of entitlements, and residual disputes. The Court accepted the Committee's recommendations on apportionment of liabilities (based on the Union of India's affidavit dated 22.12.2023), on the applicable Pay Revision Commissions (only those formally adopted before the Corporations became defunct), and on the structured mechanism for EPF dues. However, three residual issues required further adjudication: (i) identification and verification of remaining untraceable employees/legal heirs; (ii) entitlement of daily‑wage workmen and legal heirs to lump‑sum compensation; and (iii) entitlement to interest on delayed payments. The matter was listed for further hearing on 1st September 2026. The Court also directed an additional honorarium of Rs.35 lakhs to be paid to Justice Dinesh Maheshwari (Retd.), shared equally by the two States.

1. Basic Information of the Judgment

Case Title: Bihar State Ardh Sarkari Arajpati Karamchari Maha Sangh and Others v. State of Bihar and Others

Citation: 2026 INSC 607

Writ Petition (Civil) No.: 932 of 2022

Bench: Justice Sandeep Mehta &  Justice Vikram Nath

Date of Decision: May 29, 2026

Court: Supreme Court of India (Civil Original Jurisdiction)

Nature of Proceedings: Writ petition under Article 32 of the Constitution seeking directions for payment of salaries, retiral dues and other emoluments to employees of five State‑owned Corporations affected by the bifurcation of the State of Bihar.

2. Legal Framework

Major Laws and Provisions Involved

• Constitution of India, 1950 – Article 21 (right to livelihood and dignity), Article 32 (writ jurisdiction of Supreme Court).

• Bihar Reorganisation Act, 2000 – Provisions for apportionment of assets and liabilities between successor States of Bihar and Jharkhand.

• Employees' Provident Fund and Miscellaneous Provisions Act, 1952 – Section 7Q (interest on delayed payment of provident fund dues – 12% per annum).

• Industrial Disputes Act, 1947 – Not specifically invoked but relevant to wages and retiral benefits.

• Service rules of the respective Corporations – Governing pay revisions, gratuity, leave encashment, etc.

Key Precedents Cited and Applied

• Kapila Hingorani v. State of Bihar (2003-2005 proceedings) – This Court had earlier dealt with the plight of employees of State Corporations and directed deposit of Rs.125 crores as an interim arrangement; observed that the State could not absolve itself of responsibility in the face of a humanitarian crisis.

3. Relevant Facts

Following the bifurcation of the erstwhile State of Bihar under the Bihar Reorganisation Act, 2000, the assets and liabilities of five State‑owned Corporations were required to be apportioned between the successor States of Bihar and Jharkhand. The process remained unresolved for nearly 25 years. Thousands of employees were denied salaries, retiral dues, pensionary benefits and other emoluments, leading to grave humanitarian consequences including destitution and reported instances of suicides and starvation deaths among affected employees and their family members.

The issue had previously engaged the attention of this Court in Kapila Hingorani v. State of Bihar, wherein an interim arrangement of Rs.125 crores was directed to be deposited. However, the core problem of apportionment and payment remained unresolved.

The present writ petition (W.P. (C) No. 932 of 2022) was filed by the employees' association seeking completion of the bifurcation process and release of outstanding dues.

On 9th October 2023, the Court directed the Union of India and the States of Bihar and Jharkhand to jointly deliberate and arrive at a settlement. An administrative committee submitted a report in December 2023 indicating the extent of liabilities, but substantial disagreements persisted regarding geographical allocation of employees, apportionment of salary dues and interest, and non‑availability of original service records.

Given the extraordinary complexity, the Court constituted a Committee under the Chairmanship of Hon'ble Mr. Justice Dinesh Maheshwari (Retd.), Supreme Court of India, with the following terms of reference: (1) fixation of proportional liabilities of both States towards salaries and other emoluments; (2) identification of employees/family members of deceased employees, including findings on service tenure and period of deprivation; (3) entitlement of erstwhile employees to receive salary and/or retiral benefits as per extant statutes or rules; (4) any other matter relevant to the controversy.

The Committee held 25 meetings from 7th April 2025 to 31st January 2026, received oral and written submissions, examined status reports, and issued procedural orders. It submitted a final report dated 30th April 2026.

The report recorded that out of 2,274 verified employees, dues had been disbursed to 2,017 employees. 24 cases were pending document verification, and 231 employees were untraceable despite exhaustive efforts (public notices, local enquiries, coordination with law enforcement). On apportionment of liabilities, the Committee relied on the affidavit dated 22nd December 2023 filed by the Union of India, which tabulated the total financial liability apportioned to each State. On pay revisions, the Committee held that only Pay Revision Commissions formally adopted by the Corporations before they became defunct (4th PRC for most, 5th for Forest Development Corporation) were applicable; subsequent PRCs could not be claimed. On daily‑wage employees, the Committee held that payment at the minimum wage rate prevailing in 1992 (Rs.42.50 per day) until retirement/cessation was reasonable; no claim for subsequently revised minimum wages could be sustained. On EPF dues, the Committee recommended that where accounts could not be reconciled or reactivated, the States shall directly pay both employer and employee contributions together with statutory interest under Section 7Q of the EPF Act (12% per annum). On compensation for families of deceased employees, the Committee noted the absence of statutory provision but suggested that the Court, in its equitable jurisdiction, may consider quantified compensation for deaths demonstrably attributable to deprivation caused by non‑payment. On interest on delayed dues, the Committee recommended 7.5% per annum on salary arrears and 12% per annum on provident fund dues.

The Court accepted the Committee's recommendations on apportionment of liabilities, applicable pay revisions, and the structured mechanism for EPF dues. However, three residual issues were identified for further judicial consideration: (i) identification and verification of remaining employees/heirs (including the untraceable cases); (ii) entitlement of daily‑wage workmen and legal heirs to lump‑sum compensation; (iii) entitlement to and determination of interest on delayed payments. The matter was listed for further hearing on 1st September 2026.

4. Issues

Issue No. 1: Whether the apportionment of liabilities between the States of Bihar and Jharkhand, as determined by the Union of India's affidavit dated 22.12.2023, should be accepted as binding.

Issue No. 2: Whether employees of the defunct Corporations are entitled to pay revisions under Pay Revision Commissions subsequent to the ones formally adopted by the Corporations before they became defunct.

Issue No. 3: Whether daily‑wage employees are entitled to payment at revised minimum wage rates for periods when no work was actually rendered, or whether the payment at the 1992 minimum wage rate (Rs.42.50 per day) constitutes a reasonable humanitarian arrangement.

Issue No. 4: What mechanism should be adopted for payment of Employees' Provident Fund dues where accounts cannot be reconciled or reactivated.

Issue No. 5: Whether legal heirs of employees who died during the period of prolonged deprivation are entitled to compensation, and if so, on what basis.

Issue No. 6: What rate of interest should be awarded on delayed payment of salary arrears and provident fund dues.

Issue No. 7: What further directions are required for identification and verification of the remaining untraceable employees and for completion of pending document verification.

5. Ratio Decidendi

A. The Court accepted the Committee's recommendation on apportionment of liabilities (Para 37.i).

The Court held that the fixation and apportionment of inter se liability of the respective States towards payment of salaries, retiral dues and other emoluments shall stand resolved in terms of the allocation and computation determined by the Committee in paragraph 8.2 of the Final Report, i.e., on the basis of the Affidavit dated 22nd December 2023 furnished on behalf of the Union of India. The concerned States shall remain bound to discharge their respective liabilities accordingly, if not already discharged.

B. No entitlement to subsequent Pay Revision Commissions (Para 37.ii).

The determination of the applicable Pay Revision Commission shall stand confined to the Pay Revision Commission(s) duly adopted by the concerned Corporations prior to their becoming defunct. Consequently, no entitlement shall accrue in favour of the employees towards benefits arising from any subsequent Pay Revision Commissions which were never formally adopted by the competent authorities of the respective Corporations.

C. Structured mechanism for EPF dues (Para 37.iii).

The determination, computation and disbursal of dues payable towards Employees' Provident Fund contributions and allied statutory benefits shall be undertaken in accordance with the structured mechanism recommended by the Committee. Where reconciliation, tracing or reactivation of EPF accounts is no longer feasible, the concerned States shall directly disburse to the beneficiaries both the employer's and employee's contributions together with accrued statutory interest under Section 7Q of the EPF Act.

D. Residual issues requiring further adjudication (Para 38).

Three issues survived for independent judicial consideration: (i) identification and verification of remaining employees/workmen and/or legal heirs in cases where claims are yet to attain finality; (ii) entitlement of daily‑wage workmen and legal heirs to lump‑sum compensation and/or any other form of monetary, rehabilitative or welfare support including payment of due wages; (iii) entitlement to and determination of appropriate interest on delayed payment of salaries/wages, retiral dues, provident fund amounts and other consequential emoluments.

6. New Legal Principles Established / Reiterated

• In the absence of a subsisting employer‑employee relationship and in the absence of any statutory or contractual mandate, employees of defunct State Corporations cannot claim the benefit of Pay Revision Commissions that were never formally adopted by the competent authority of the Corporation prior to its cessation of functioning.

• Where a Corporation has become defunct and no work was rendered for extended periods, the payment of wages at the minimum wage rate prevailing at the time of cessation (here, Rs.42.50 per day from 1992) may be treated as a reasonable and equitable humanitarian arrangement, and employees cannot claim enhanced rates under subsequently revised minimum wage notifications as a matter of vested legal right.

• The obligation to disburse provident fund dues survives the dissolution or functional collapse of the employer Corporation. Where EPF accounts cannot be traced or reactivated, the successor States are directly liable to pay both employer and employee contributions together with statutory interest under Section 7Q of the EPF Act (12% per annum).

• The right to livelihood and dignity under Article 21 of the Constitution is implicated when State‑owned Corporations fail to pay salaries and retiral benefits for decades, causing destitution, suicides and starvation deaths. The Court may, in its equitable jurisdiction, consider awarding compensation to legal heirs of employees whose deaths are demonstrably attributable to such deprivation, even in the absence of specific statutory provisions.

• The Supreme Court may constitute a Committee headed by a retired Judge of the Court to conduct a comprehensive enquiry into complex factual disputes involving multiple State Governments, public sector undertakings, and thousands of affected individuals, and may accept the Committee's findings and recommendations on most issues while retaining residual issues for judicial determination.

7. Court's Examination and Analysis

The Court first recounted the background of the prolonged humanitarian crisis arising from non‑payment of salaries and retiral benefits to employees of five State‑owned Corporations following the bifurcation of Bihar in 2000. It noted that the matter had been pending for nearly 25 years and that earlier proceedings (Kapila Hingorani) had only resulted in interim relief.

The Court then reviewed the constitution of the Committee headed by Justice Dinesh Maheshwari (Retd.) and the Committee's extensive work over 25 meetings. The final report was perused minutely.

On the first issue (apportionment of liabilities), the Court found that the Union of India's affidavit dated 22.12.2023 provided a clear tabulated allocation. The Committee had accepted this as the basis. The Court agreed, holding that the States of Bihar and Jharkhand are bound by this allocation.

On the second issue (pay revisions), the Committee had examined the records of each Corporation and found that only the 4th Pay Revision Commission (and for the Forest Development Corporation, the 5th) had been formally adopted by the respective Boards before the Corporations became defunct. No resolution adopted any subsequent PRC. The Court accepted this finding, holding that in the absence of a subsisting employer‑employee framework or statutory mandate, no enforceable right to subsequent pay revisions can accrue.

On the third issue (daily‑wage employees), the Committee found that the States had extended notional continuity by paying the minimum wage rate prevailing in 1992 (Rs.42.50 per day) till the respective dates of retirement or cessation. The Court regarded this as a reasonable, equitable and humanitarian arrangement. It rejected the claim for payment at subsequently revised minimum wage rates for periods when no work was actually rendered, as the doctrine of payment of wages presupposes rendering of service.

On the fourth issue (EPF dues), the Committee emphasised that provident fund accumulations constitute a vested statutory right. Where accounts could not be reconciled or reactivated, the Committee recommended that the States directly pay both contributions with interest under Section 7Q of the EPF Act (12% per annum). The Court accepted this recommendation.

On the fifth issue (compensation for deaths), the Committee noted the absence of statutory provision but drew attention to the grave humanitarian consequences. The Court did not finally decide this issue but listed it as a residual issue for further hearing, indicating that it may consider awarding quantified compensation in exercise of its equitable jurisdiction.

On the sixth issue (interest), the Committee recommended 7.5% per annum on salary arrears and 12% per annum on provident fund dues. The Court listed this as a residual issue for further adjudication.

The Court also directed an additional honorarium of Rs.35 lakhs to be paid to Justice Dinesh Maheshwari (Retd.), shared equally by the two States, in recognition of his work.

The matter was listed for further hearing on 1st September 2026, with directions for the parties to file written submissions and for the States to file compliance affidavits.

8. Critical Analysis

Strengths: The judgment is a masterful example of institutional problem‑solving by the Supreme Court. By constituting a Committee headed by a retired Judge of the Court, the Court was able to obtain a detailed, evidence‑based report on a highly complex factual dispute involving multiple States, thousands of employees, decades of delay, and intricate financial and service‑related issues. The Committee's recommendations provided a clear framework for resolution. The Court accepted the bulk of these recommendations, thereby bringing near‑finality to a 25‑year‑old dispute for the vast majority of employees (2,017 out of 2,274). The Court's recognition of the humanitarian dimension (suicides, starvation deaths) and its willingness to consider compensation and interest in the residual hearing demonstrates sensitivity to the human cost of administrative inaction. The honorarium to the Committee Chair is a gracious acknowledgment of the pro bono service rendered.

Potential concerns: The judgment does not finally resolve the three residual issues; the matter will continue for at least another hearing (1st September 2026). This means that for the 231 untraceable employees, the 24 employees with pending document verification, and the claims for compensation and interest, finality is still some distance away. However, given the complexity, this is understandable. Another concern is that the Court accepted the Committee's recommendation on daily‑wage wages (payment at 1992 rates) without explicit discussion of whether the States had any obligation to pay higher rates under the Minimum Wages Act for the period when the employees were notionally continued. The Committee's reasoning that "payment of wages presupposes rendering of service" is sound, but one could argue that if the States had kept the employees on the rolls (notional continuity), they ought to have paid the statutory minimum wage for the entire period, not a frozen 1992 rate. However, the Court treated the 1992 rate as a "reasonable, equitable and humanitarian arrangement" – a pragmatic compromise given that no work was actually performed.

Practical impact: This judgment provides a template for resolving large‑scale inter‑State disputes arising from reorganisation of States, especially concerning public sector employees. It demonstrates that the Supreme Court can utilise expert committees headed by retired judges to gather facts and make recommendations, thereby lightening the Court's own adjudicatory burden while ensuring thoroughness. For the employees, the judgment brings substantial relief for the majority, with only residual issues remaining. For the States, the judgment provides clarity on their liabilities (apportionment, pay revisions, EPF mechanism) and sets deadlines for compliance.

9. Final Outcome

The Writ Petition was partially allowed and partially listed for further hearing.

• The Court accepted the Committee's recommendations on apportionment of liabilities (based on Union of India's affidavit dated 22.12.2023), on applicable Pay Revision Commissions (only those formally adopted before the Corporations became defunct), and on the structured mechanism for EPF dues (direct payment of both contributions with interest where accounts cannot be reconciled).

• The following three residual issues were listed for further judicial consideration and adjudication:
  (i) Identification and verification of remaining employees/workmen and/or legal heirs where claims are yet to attain finality.
  (ii) Entitlement of daily‑wage workmen and legal heirs to lump‑sum compensation and/or other monetary, rehabilitative or welfare support.
  (iii) Entitlement to and determination of appropriate interest on delayed payment of salaries/wages, retiral dues, provident fund amounts and other consequential emoluments.

• The Court directed the States of Bihar and Jharkhand to file compliance affidavits placing on record steps taken towards implementation of the directions issued.

• The Court directed an additional honorarium of Rs.35,00,000 (Thirty‑Five Lakhs) to be paid to Hon'ble Mr. Justice Dinesh Maheshwari (Retd.), shared equally by the States of Bihar and Jharkhand, within four weeks.

• The matter was listed as part‑heard on 1st September 2026 for further hearing.

10. Practical Application

For employees of defunct State Corporations in inter‑State reorganisation disputes: Approach the Supreme Court under Article 32 if the dispute remains unresolved for decades. The Court may constitute a high‑level committee to investigate and recommend solutions. Ensure that you provide all available service records, identity proofs, and bank account details to the authorities to avoid being categorised as "untraceable". If you are one of the 231 untraceable employees or 24 with pending document verification, immediately contact the designated nodal officers of the respective Corporations and the State Governments to complete the verification process. You may be entitled to back wages (at 1992 minimum wage rates for daily‑wage employees, or at the adopted pay revision rates for regular employees), provident fund dues with interest, and possibly compensation if you or your family members suffered extreme deprivation.

For State Governments (Bihar and Jharkhand): You are bound by the apportionment of liabilities as per the Union of India's affidavit dated 22.12.2023. Discharge your respective shares immediately if not already done. For EPF dues where accounts cannot be reconciled, pay both contributions with interest under Section 7Q of the EPF Act directly to the employees/heirs. For the 231 untraceable employees, make renewed efforts to trace them through public notices, social welfare departments, and coordination with law enforcement. For the 24 cases with pending document verification, appoint dedicated nodal officers to expedite the process. File compliance affidavits as directed. Be prepared to address the residual issues of compensation and interest at the next hearing.

For legal heirs of deceased employees: If your deceased relative was an employee of one of the five Corporations and died during the period of non‑payment, you may be entitled to receive the outstanding dues of the employee (salaries, retiral benefits, EPF) as well as possibly compensation. Gather all documents: death certificate, service records (if available), proof of relationship, and any evidence linking the death to deprivation caused by non‑payment (e.g., medical reports, suicide note, newspaper reports). File a claim before the designated nodal officer. If the claim is not processed, you may approach the Court through the petitioner‑association.

For lawyers handling similar inter‑State disputes: Consider proposing the appointment of a retired Judge as a Committee head to conduct a detailed factual enquiry. The Committee can issue procedural orders, call for evidence, and submit a report with recommendations. This approach is more efficient than the Court itself attempting to resolve complex factual disputes through adversarial proceedings. Ensure that the Committee's terms of reference are comprehensive and include fixation of liabilities, identification of beneficiaries, determination of entitlements, and resolution of ancillary issues (interest, compensation, procedural hurdles).

For the Court in similar matters: The constitution of a Committee under the chairmanship of a retired Judge of the Supreme Court (or a retired High Court Chief Justice) is a powerful tool to resolve complex, multi‑party, long‑pending disputes involving factual controversies. The Committee can hold hearings, summon documents, issue directions to State authorities, and submit periodic reports. The Court retains ultimate adjudicatory authority over legal issues, but the Committee's factual findings and recommendations can be accepted unless patently erroneous. This mechanism reduces the Court's workload while ensuring thorough fact‑finding.

11.  Court Lines

Line 1 (Humanitarian dimension – Para 3):
"The dispute, therefore, ceased to remain a mere matter of financial adjustment between two successor States and assumed the character of a significant human rights and constitutional concern directly implicating the right to livelihood and dignity guaranteed under Article 21 of the Constitution of India."

Line 2 (No entitlement to subsequent pay revisions – Para 22):
"The Committee has opined that the petitioners' claim seeking extension of benefits arising from subsequent Pay Revision Commissions is not legally sustainable... no resolution, decision or statutory adoption of any subsequent Pay Revision Commission was ever undertaken by the competent authorities prior to cessation of the corporations' functioning."

Line 3 (Daily‑wage payment at 1992 rates – Para 25):
"The Committee has observed that the doctrine underlying payment of wages necessarily presupposes rendering of service and that, in the peculiar circumstances after closure... the States nevertheless extended notional continuity by providing the minimum wage rates prevailing in the year 1992 i.e., Rs. 42.50 per day... The Committee has regarded the said measure as a reasonable, equitable and humanitarian arrangement."

Line 4 (EPF as vested right – Para 27):
"The Committee has emphatically observed that provident fund accumulations constitute a vested statutory right of the employees and partake the character of protected retiral benefits incapable of being defeated by administrative lapses, financial incapacity or procedural impediments."

Line 5 (Residual issues – Para 38):
"Notwithstanding the substantial resolution of the disputes... following residual issues still survive which, in our considered view, require independent judicial consideration and adjudication by this Court having regard to the nature of the claims involved and the legal consequences flowing therefrom."

Line 6 (Compensation for deaths – Para 31-32):
"The Committee has taken note of the grave humanitarian consequences resulting from prolonged denial of salaries and retrial dues and the severe hardship suffered by several families... the Committee has suggested that this Court, in exercise of its equitable and constitutional jurisdiction, may consider grant of an appropriate quantified compensation to the legal heirs of those employees whose deaths are demonstrably attributable to the extreme deprivation and destitution occasioned by non‑payment of legitimate dues."

Line 7 (Interest rates – Para 34):
"The Committee has accordingly recommended that interest at the rate of 7.5% per annum be awarded on delayed payment of salary arrears and interest at the rate of 12% per annum on delayed provident fund dues, the latter being in consonance with the statutory and compensatory character of provident fund entitlements."

12. Legal Strategy Insight

For an employee association representing workers of defunct State Corporations: Do not wait for the State to resolve inter‑State disputes on its own. File a writ petition under Article 32 immediately. Bring to the Court's attention the humanitarian consequences (non‑payment for decades, destitution, suicides). Request the Court to constitute an independent high‑level committee (preferably headed by a retired Judge) to investigate and recommend a resolution. Cooperate fully with the committee by providing all available service records, lists of employees, and evidence of deprivation. If the committee issues recommendations that are largely favourable, accept them. Only challenge specific recommendations that are legally unsustainable (e.g., denial of statutory benefits). Keep track of "untraceable" employees and make efforts to trace them through public notices and social media; otherwise, their claims may be permanently closed.

For a State Government (Bihar or Jharkhand) facing such a petition: Do not resist the appointment of a committee; instead, cooperate and provide all records. Acknowledge the humanitarian dimension and propose a pragmatic resolution. If the committee recommends apportionment of liabilities based on available data, accept it to avoid prolonged litigation. For pay revision claims, argue that only those PRCs formally adopted by the Corporation's Board before it became defunct are applicable – subsequent PRCs cannot be imposed on a non‑existent employer. For daily‑wage employees, argue that wages are paid for work rendered; where no work was performed, payment at a notional rate (e.g., 1992 minimum wage) is a humanitarian gesture, not a statutory right. However, for provident fund dues, concede that it is a statutory right and agree to pay both contributions with interest.

For a lawyer representing employees in an inter‑State reorganisation dispute: Structure the petition to highlight the violation of Article 21 (right to livelihood). Demand an interim relief (e.g., a substantial deposit by the States) to alleviate immediate distress. If the Court constitutes a committee, actively participate by filing written submissions and providing evidence. If the committee's recommendations are unfavourable on certain issues (e.g., denial of subsequent pay revisions, freezing wages at 1992 rates), preserve those issues for judicial determination by the Court. Do not accept them as binding if they are legally incorrect. At the final hearing before the Court, argue that the committee's findings are advisory and that the Court must independently adjudicate legal questions (e.g., whether the State can continue to notionally employ workers without paying the statutory minimum wage as revised from time to time).

For a court dealing with a similar complex inter‑State dispute: First, attempt mediation or negotiation between the States. If that fails, consider appointing a committee headed by a retired Judge of the Supreme Court or a retired Chief Justice of a High Court. Define clear terms of reference. Give the committee sufficient time (6‑12 months) and the power to call for documents, summon witnesses, and issue procedural directions. Receive the committee's report, invite objections, and then adjudicate only the residual legal issues. This approach is efficient, cost‑effective, and likely to result in a more equitable outcome than piecemeal litigation.

For legal heirs of deceased employees who died during the period of non‑payment: Document everything. If the employee died by suicide or due to starvation/illness directly attributable to non‑payment of wages, collect medical records, death certificate, police reports (if any), and affidavits from family members. File a claim before the designated authority of the Corporation or the State. If the claim is rejected or ignored, move the Supreme Court through the pending writ petition (if already pending) or file an intervention application. Rely on the Committee's observation that the Court may consider awarding quantified compensation in its equitable jurisdiction. Be prepared to prove causation between non‑payment and death – a high evidentiary burden, but possible with credible evidence.