Supreme Court Upholds Maternity Rights of Contractual Employees (Based on Dr. Kavita Yadav vs. Secretary, Ministry of Health and Family Welfare Department & Ors., (2024) 1 SCC 421)
Introduction
In a landmark judgment that reinforces gender justice and workplace equity, the Supreme Court in Dr. Kavita Yadav vs. Secretary, Ministry of Health and Family Welfare Department & Ors., [(2024) 1 SCC 421], held that contractual female employees are entitled to full maternity benefits under the Maternity Benefit Act, 1961, even if such benefits extend beyond the tenure of their contract.
Background of the Case
Dr. Kavita Yadav, a Senior Resident (Pathology) in a Delhi government hospital, was engaged on a contractual basis for three consecutive years. Just days before the expiration of her final extension, she applied for maternity leave under Section 5 of the Maternity Benefit Act, 1961. Her employer granted her only 11 days of leave, stating that since her contract ended on 11th June 2017, no benefits could be provided beyond that date.
Her claim for the full statutory leave of 26 weeks was rejected by the employer, the Central Administrative Tribunal, and later by the Delhi High Court — all citing the expiry of her contractual term.
Supreme Court’s Analysis
The Supreme Court reversed the lower court rulings and emphatically held:
– Maternity benefits are not co-terminus with contractual tenure.
– Once a woman fulfills the eligibility criteria under Section 5(2) (i.e., 80 days of service), she acquires a statutory right to receive full maternity benefits.
– Termination or non-renewal of a contract during maternity leave constitutes “discharge” under Section 12(2)(a) of the Act, attracting legal prohibition.
– Section 27 of the Act gives it overriding effect over any inconsistent contracts, agreements, or rules.
The Court drew strength from previous rulings such as:
– Municipal Corporation of Delhi vs. Female Workers (Muster Roll) [(2000) 3 SCC 224], and
– Deepika Singh vs. CAT [(2022) 7 SCR 557],
where it was held that benefits under maternity laws apply even to daily wagers or casual employees.
Significance of the Judgment
- Reinforces Women’s Reproductive Rights: Recognizes the autonomy of women to become mothers without risking their livelihood.
- Bridges the Gap Between Permanent and Contractual Workers: Ensures parity in the application of social welfare legislation.
- Legislative Intent Upheld: The court correctly interpreted the Act in the light of Articles 14, 15, 39, 42, and 43 of the Constitution of India.
- Precedent-Setting: This case is a crucial precedent for all future disputes involving maternity benefits for non-permanent employees.
Conclusion
The Supreme Court has set a strong and progressive message that maternity benefits are not just privileges but enforceable rights. This verdict will impact thousands of women working under temporary or fixed-term contracts in hospitals, educational institutions, and government projects.
It is a decisive affirmation that constitutional principles of equality and dignity do not differentiate between permanent and contractual workers — especially when it comes to motherhood.