Anganwadi Workers are employees entitled to gratuity as Anganwadi Centres constitute a single establishment.

The private respondents are Anganwadi Workers (AWWs) and Anganwadi Helpers (AWHs) engaged under the Integrated Child Development Scheme (ICDS) in Tripura.

Their services were discontinued between 2021 and 2023 upon reaching the retirement age of 60.

They submitted representations for gratuity and post-retiral benefits, which were rejected by the Director of Social Welfare and Social Education on 11.08.2023.

The State contended that AWWs/AWHs are honorary workers receiving an "honorarium," not "wages," and are thus ineligible for gratuity under the Payment of Gratuity Act, 1972.

The respondents filed writ petitions, which a Single Judge allowed by relying on the Supreme Court precedent in Maniben Maganbhai Bhariya v. District Development Officer, Dahod & Ors. (2022).

The State of Tripura appealed, arguing that Maniben was specific to Gujarat and that individual Anganwadi Centers (AWCs) do not meet the "establishment" threshold of employing 10 or more persons.

1. Whether the provisions of the Payment of Gratuity Act, 1972 are applicable to AWWs and AWHs engaged in the State of Tripura.

2. Whether the Supreme Court’s judgment in Maniben Maganbhai Bhariya (2022) is binding on the State of Tripura under Article 141 of the Constitution, despite the State not being a party to that case.

3. Whether individual Anganwadi Centers should be treated as separate establishments or as part of a single department for the purpose of the numerical threshold under Section 1(3)(b) of the Act.

Section 1(3)(b) of the Payment of Gratuity Act, 1972, which extends the Act to establishments with ten or more employees.

Article 141 of the Constitution of India, establishing that Supreme Court judgments are binding on all authorities.

National Food Security Act, 2013 (Sections 4-6) and the Right of Children to Free and Compulsory Education Act, 2009 (Section 11), which grant statutory status to the duties performed by AWWs/AWHs.

Precedent in Maniben Maganbhai Bhariya v. District Development Officer, Dahod & Ors. (2022) 16 SCC 343, which classified AWWs/AWHs as "employees" holding "statutory posts" and their honorariums as "wages".

The court rejected the State’s argument that AWWs/AWHs are merely honorary workers, noting that the Supreme Court in Maniben had already determined that the nature of their duties—now codified under the National Food Security Act and the Right to Education Act—transforms their role into statutory posts.

The court observed that while the State calls the remuneration an "honorarium," it effectively constitutes "wages" for the purpose of social security legislation.

Regarding the numerical threshold, the court found that AWCs do not function as isolated units; rather, they operate under the unified "umbrella" of the Social Welfare Department, which manages recruitment, guidelines, and pension schemes centrally.

The AWC system as a whole constitutes an "establishment" under the Act.

The court dismissed the State’s contention regarding Article 141, holding that a declaration of law by the Supreme Court is a judgment in rem and applies across India regardless of which state was a party to the original litigation.

Financial implications were held to be secondary to the statutory mandate of social security.

The court directed the Appellants to calculate and pay the gratuity to the respondents based on their eligibility, along with interest at 7% per annum starting from 30 days after their respective retirement dates until the date of actual payment.

The orders dated 11.08.2023, which had rejected the claims for gratuity, were officially set aside.