Case of Union of India vs Heavy Vehicles Factory Employees Union, SC Judgement Dated 20th January 2026. The apex court held that compensatory allowances such as House Rent Allowance (HRA), Transport Allowance, Clothing and Washing Allowance and Small Family Allowance must be included while computing overtime wages, as they fall within the expression “ordinary rate of wages” under Section 59(2) of Factories Act. The Court was of the opinion that different Ministries cannot assign varying meanings to a statutory provision when its intent is clear from the plain reading of Section 59(2) of the Act.