ABC Ltd. is a medium-sized manufacturing company that produces automotive parts. The company has a workforce of 150 employees, including both production line workers and administrative staff. ABC Ltd. typically awards an

Section 9 of Payment of Bonus Act, 1965 deals with Disqualification for Bonus According to Section 9 of the act an employee shall be disqualified from receiving bonus under the Payment of Bonus Act, 1965, if he is dismissed from service for: Fraud, or Riotous or violent behavior while on the premises of the establishment; or Theft, misappropriation or sabotage of any property of the establishment This provision is based on the recommendation of Bonus Commission, which stated that: After all, bonus can only be shared by those workers who promote the stability and well-being of the industry, not by those who positively exhibit disruptive tendencies. Bonuses, without a doubt, impose a duty of good behaviour. In Gammon India Ltd Vs Niranjan Das 6, the Court held that an employee who is dismissed from service for fraud, riotous or aggressive behaviour on the premises of the company, or who is guilty of theft, misappropriation, or sabotage of any establishment's property is disqualified from receiving bonus for the accounting year under section 9 of the Payment of Bonus Act, 1965. A dismissed employee who has been reinstated with back pay has evidently not committed the above crimes and has not been fired. As a result, he is entitled to a bonus. In view of the above, those employees of ABC Limited, who are guilty of theft are not entitled to payment of bonus.