Gratuity orders must be enforced through the recovery mechanism under Section 8 of the Payment of Gratuity Act.

In W.P. No. 20157 of 2024, retired employees of HMT Machine Tools Ltd. obtained orders from the Controlling Authority under the Payment of Gratuity Act, 1972 directing payment of gratuity with simple interest at 10% per annum.

The company later paid the gratuity but, according to the petitioners, did not pay the interest; the Deputy Commissioner had earlier initiated recovery steps, and the petitioners sought action on their representations for recovery of the balance

In W.P. No. 7183 of 2025, two petitioners had Controlling Authority orders directing payment of gratuity with 10% simple interest, while the remaining petitioners had no such orders identified in the judgment.

They sought payment or implementation of the orders and relief concerning the other petitioners’ gratuity claims

1. Whether the petitioners in W.P. No. 20157 of 2024 could obtain a direction requiring the revenue authorities to act on their representations for recovery of unpaid interest under the Payment of Gratuity Act and the Karnataka Land Revenue Act

2. Whether the petitioners in W.P. No. 7183 of 2025 should pursue the statutory recovery mechanism under Section 8 of the Payment of Gratuity Act to enforce the Controlling Authority’s orders, and how the remaining petitioners could pursue their gratuity claims

Section 8 of the Payment of Gratuity Act, 1972 provides a statutory mechanism for recovery where an amount payable under the Act is not paid, including recovery through the competent authority.

The Court also referred, in W.P. No. 20157 of 2024, to the Karnataka Land Revenue Act, 1964 as part of the legal framework governing recovery action

No judicial precedents were cited or applied.

In W.P. No. 20157 of 2024, the Court did not itself determine the amount of interest due or order its payment; it directed the revenue authorities to consider the petitioners’ representations and take appropriate action under the applicable statutes

In W.P. No. 7183 of 2025, because Section 8 provides a route to enforce the Controlling Authority’s orders, the Court reserved liberty to the petitioners with such orders to approach the Deputy Commissioner under that provision.

For the other petitioners, it directed consideration of any representations, supported by relevant records, in accordance with law

W.P. No. 7183 of 2025 was disposed of by reserving liberty to the petitioners with Controlling Authority orders to seek implementation under Section 8, and directing that the remaining petitioners’ representations be considered in accordance with law within three months