Executive Summary

The Employees’ State Insurance Corporation (ESIC), established under the Employees’ State Insurance Act, 1948 (the ESI Act), operates as one of India’s most significant social security institutions, providing comprehensive health and social insurance coverage to workers in organised sector establishments. The wage ceiling for ESI coverage — the income threshold below which an employee is mandatorily brought within the ambit of ESIC — has historically served as the primary determinant of the scheme’s coverage breadth and esic wage ceiling employer impact. With the government having under active consideration a proposal to raise the threshold from its current level as of mid-2025, it is important for employers to understand the precise mechanics of the existing regime, the implications of a ceiling revision, and the compliance adjustments that would follow.

It must be emphasised at the outset that, as of June 2026, no formal gazette notification effectuating a revision to the ESIC wage ceiling has been issued. This article treats the ceiling revision as a prospective policy development and frames its analysis accordingly. Employers should monitor the Official Gazette for any formal notification before recalibrating their compliance posture.

This article provides a detailed examination of the ESI Act framework, the definition of wages for ESI purposes, contribution rates, the nature of ESIC benefits, and the anticipated impact on employer obligations should the wage ceiling be revised upward.

Statutory Framework

The Employees’ State Insurance Act, 1948

The ESI Act, 1948 is the parent legislation governing the Employees’ State Insurance scheme. The Act extends, under Section 1(5), to all factories as defined therein, and has been progressively extended by the appropriate government to other classes of establishments, currently covering establishments with ten or more employees. The Central Government and state governments have extended the Act to a wide range of establishment types, including shops, hotels, restaurants, cinemas, road transport undertakings, newspaper establishments, and educational and medical institutions, among others.

Section 2(22) ESI Act: Definition of Wages

The definition of “wages” under Section 2(22) of the ESI Act is central to computing both the wage ceiling and contribution liability. Section 2(22) defines wages to mean all remuneration paid or payable in cash to an employee, if the terms of the contract of employment — express or implied — were fulfilled. This definition encompasses basic pay, dearness allowance, and other allowances payable to the employee as part of the employment contract. However, the definition specifically excludes: any contribution paid by the employer to any pension fund or provident fund, or under the ESI Act itself; any travelling allowance or the value of any travelling concession; any sum paid to the employee to defray special expenses entailed on the employee by the nature of employment; and any gratuity payable on discharge.

House Rent Allowance (HRA) is excluded from the definition of wages for ESI purposes by virtue of established administrative practice and regulatory interpretation, though the precise boundaries of what constitutes wages for ESI purposes have on occasion been the subject of dispute between employers and ESIC authorities. The treatment of other allowances — special allowances, performance pay, and flexi-pay components — requires careful examination against the Section 2(22) definition in each case.

The Wage Ceiling and Contribution Structure

The wage ceiling for ESI coverage is fixed by the Central Government through notification under Section 2(9) of the ESI Act, which defines an “employee” as any person employed for wages in or in connection with the work of a factory or establishment to which the Act applies. The current wage ceiling stands at Rs. 21,000 per month, having been raised from the previous threshold of Rs. 15,000 per month by the Central Government through a notification that came into effect in January 2017. A higher threshold of Rs. 25,000 per month applies specifically to persons with disabilities.

Employees whose monthly wages — computed in accordance with the Section 2(22) definition — do not exceed the applicable ceiling are “Insured Persons” under the ESI Act and are mandatorily covered. Employees whose wages exceed the ceiling fall outside the mandatory coverage framework, though certain voluntary continuation provisions exist for employees who exceed the ceiling during a contribution period.

The contribution rates under the ESI Act are prescribed by the Central Government. As of June 2026, the employer’s contribution stands at 3.25 percent of the wages payable to the employee, and the employee’s contribution stands at 0.75 percent of the wages payable, yielding a combined contribution of 4 percent of wages. Employees earning wages up to Rs. 176 per day are exempt from the employee share of contribution, though the employer’s contribution remains payable in respect of such employees.

The Contribution Period Mechanism

The ESI Act divides the year into two contribution periods — April to September and October to March — and corresponding benefit periods. Once an employee is covered in a contribution period by virtue of wages falling below the ceiling at the commencement of that period, they remain covered for the entirety of that contribution period and the corresponding benefit period, even if their wages subsequently increase beyond the ceiling during that period. This “once covered, always covered for the period” principle prevents administrative difficulties arising from mid-period pay revisions. An employee who was covered in one contribution period but whose wages have risen above the ceiling by the commencement of the next contribution period ceases to be covered from the start of the new contribution period.

Exemptions Available Under Section 87

Section 87 of the ESI Act empowers the appropriate government — Central or State, depending on the nature of the establishment — to exempt any factory or establishment or class of factories or establishments from the operation of the Act, either wholly or partially, subject to conditions. Such exemptions are typically granted where equivalent or superior benefits are provided through alternative arrangements — such as group medical insurance schemes — subject to certification and periodic review by ESIC authorities. The process for obtaining exemptions is administrative in nature and involves submission of evidence that the alternative benefits meet or exceed the ESIC benefit package, followed by a grant of exemption subject to ongoing compliance monitoring.

ESIC Benefits: The Social Security Entitlement

The social security entitlements available to Insured Persons and their dependents under the ESI Act are comprehensive and include the following. Sickness Benefit is payable at approximately 70 percent of daily wages for a maximum of 91 days in a contribution year during certified sickness, and is available to Insured Persons who have made contributions for not less than 78 days in the relevant contribution period. Extended Sickness Benefit is available for specified long-term diseases for a period of up to two years, at an enhanced rate. Maternity Benefit is payable at full wages for 26 weeks for a first or second child, with the benefit period and conditions for ESI-covered employees aligned with the Maternity Benefit Act, 1961. Disablement Benefit comprises temporary disablement benefit at approximately 90 percent of daily wages for the duration of temporary disablement arising from employment injury, and permanent disablement benefit calculated based on the degree of disability certified by a medical board. Dependants’ Benefit is payable as a monthly pension to dependants of an Insured Person who dies from an employment injury, with the rate being a percentage of the wages of the deceased. Medical Benefit provides comprehensive medical care for the Insured Person and their family through ESIC hospitals, dispensaries, and empanelled private medical facilities, representing a significant in-kind social security entitlement. Funeral Expenses are payable as a lump sum to defray the cost of an Insured Person’s funeral, currently set at Rs. 15,000.

Procedural Landscape

Anticipated Impact of a Wage Ceiling Revision: The ESIC Wage Ceiling Employer Impact Analysis

Should the Central Government notify a revised wage ceiling — with policy discussions as of mid-2025 indicating possible revision to a range of Rs. 25,000 to Rs. 30,000 per month — the following impact analysis applies. This analysis is prospective and contingent upon formal notification; it does not describe the current legal position.

Coverage expansion would be the most immediate consequence. A substantial cohort of employees currently earning between Rs. 21,001 and the new ceiling would become mandatorily covered as Insured Persons. In establishments with significant numbers of employees in this salary band — which is common in sectors such as information technology-enabled services at entry levels, retail, logistics, and manufacturing — the number of covered employees could increase materially.

Employer contribution liability would increase proportionately. At the current contribution rate of 3.25 percent, an employer whose employee base in the newly covered salary band is substantial would experience a meaningful increase in payroll cost. For illustration, an employee earning Rs. 25,000 per month who becomes covered under a revised ceiling of Rs. 26,000 would generate an employer ESIC contribution of Rs. 812.50 per month (3.25 percent of Rs. 25,000), in addition to the employee’s contribution of Rs. 187.50 (0.75 percent of Rs. 25,000). Multiplied across large employee cohorts, the aggregate additional contribution burden would be significant and would need to be reflected in budget projections for the financial year in which the revision takes effect.

Payroll system and HR process adjustments would be required. Employers would need to update payroll software to reflect the revised coverage threshold, reconfigure contribution computation logic, re-register newly covered employees with ESIC, and issue them Insured Person numbers and insurance cards. HR and payroll teams would need to be trained on the revised definitions and thresholds, and employee communications would need to be issued explaining the new coverage status and associated benefits.

Interaction with exemption mechanisms would become more prominent. Employers who provide equivalent benefits through private group health insurance would have a stronger incentive to seek exemption under Section 87 if a larger proportion of their workforce becomes covered. Given the lead time involved in the exemption process, proactive engagement with ESIC authorities well before any ceiling revision comes into effect would be prudent.

Employer Action Steps If the Wage Ceiling Changes

Should the Central Government notify a revised wage ceiling, employers may consider the following sequential compliance steps:

1. Conduct a payroll audit to identify all employees currently earning above the existing ceiling of Rs. 21,000 but below the new ceiling, and quantify the additional contribution liability across the affected employee population.
2. Review the definition of “wages” under Section 2(22) for each such employee to determine the precise base on which contributions will be computed, taking care to exclude non-wage components such as HRA and travel allowance and to include all components that fall within the statutory definition.
3. Update payroll software and HR management systems to reflect the revised threshold and contribution computation, and test the updated configuration before the effective date.
4. Register newly covered employees with ESIC by submitting the requisite forms through the ESIC portal and obtaining Insured Person numbers and insurance cards for such employees.
5. Assess whether the establishment meets the criteria for exemption under Section 87 and, if so, initiate that process in advance of the revision’s effective date, recognising that exemptions are not automatic and require affirmative ESIC approval.
6. Brief senior management and finance teams on the revised employer contribution liability and its impact on the employee cost budget for the relevant financial year.
7. Communicate to affected employees regarding their new ESIC coverage status and the benefits to which they will become entitled, addressing common employee queries about card issuance, empanelled hospitals, and benefit eligibility periods.
8. Ensure compliance with the revised return-filing and contribution-remittance obligations under the ESI Act, noting that contributions are due within 21 days of the close of each calendar month, and that delays attract interest and penalties under the Act.

Key Judicial Precedents

Regional Director, ESIC v. High Land Coffee Works of P.F.X. Saldanha and Sons (1991) 3 SCC 617

The Supreme Court’s decision in Regional Director, ESIC v. High Land Coffee Works of P.F.X. Saldanha and Sons, (1991) 3 SCC 617, is a foundational precedent on the interpretation of “wages” under the ESI Act. The Court held that the definition of wages under Section 2(22) is to be construed broadly, consistent with the beneficial and social security objects of the Act, and that attempts to exclude components of remuneration from the definition — to reduce contribution liability — would be scrutinised carefully against the actual terms of the contract of employment and the nature of the payment. This decision reinforces the principle that employers must examine the character of each remuneration component carefully when computing ESI contributions and not rely solely on the label assigned to a payment in the payroll structure.

This decision carries particular relevance for the esic wage ceiling employer impact analysis, because as the ceiling rises and more employees become covered, the temptation for employers to restructure remuneration packages to minimise the ESI contribution base may increase. The jurisprudential principle established in High Land Coffee Works makes clear that such restructuring will be tested against the substantive character of the payment, not merely its designation.

Supreme Court’s Guidance on Wage Ceiling Notifications

The Supreme Court has, in several matters arising from the enforcement of ESI wage ceiling notifications, held that the Central Government’s power to fix and revise the wage ceiling through notification is a valid exercise of the delegated legislative power under the ESI Act, and that such notifications, once published in the Official Gazette, take effect from the date specified therein. Employers are bound to implement revised ceilings from the date of effect and cannot defer compliance pending internal process updates.

Conclusion

The esic wage ceiling employer impact of any upward revision would be felt most acutely by establishments with a high density of employees earning in the Rs. 21,001 to Rs. 30,000 monthly wage range, as these employees would transition from uncovered to covered status, thereby generating new and ongoing contribution obligations for their employers. While the extension of ESIC coverage to a broader employee base serves legitimate social security objectives — expanding access to medical, sickness, maternity, and disablement benefits for mid-income earners — it simultaneously imposes incremental payroll costs and compliance obligations on employers that must be planned for systematically.

The current position, as of June 2026, is that the wage ceiling remains at Rs. 21,000 per month (Rs. 25,000 for persons with disabilities) and no formal notification of a revision has been issued. Employers should monitor the Official Gazette and ESIC communications for any notification of a revised ceiling, and use the intervening period to conduct the preparatory payroll audit and system-update exercises outlined above, so that compliance can be operationalised promptly upon any formal revision. The ESI Act’s social security architecture — combining employer and employee contributions with a comprehensive menu of benefits — reflects a considered legislative determination that the costs of social insurance are to be shared between labour and capital within the organised sector, and any revision to the wage ceiling is an extension of that legislative philosophy.

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Introduction

The Supreme Court of India’s recent judgment in Mala Devi v. Union of India [1] has brought significant clarity to family pension rights of railway employees, particularly those in non-permanent positions. This landmark decision, delivered on July 17, 2025, by a bench comprising Justice Sanjay Karol and Justice Satish Chandra Sharma, addresses the critical issue of family pension entitlements for widows of deceased railway employees who served as temporary or substitute workers.

The case highlights the ongoing challenges faced by families of railway employees who dedicated their lives to serving the nation but were denied pension benefits due to technicalities in service regulations. The court’s decision reflects a progressive interpretation of social welfare legislation and emphasizes the importance of substantive justice over procedural formalities.

Legal Framework Governing Railway Pension Rights

Railway Services (Pension) Rules, 1993

The Railway Services (Pension) Rules, 1993 [2] form the cornerstone of pension administration for railway employees in India. These rules were formulated to provide comprehensive guidelines for the grant of pension and other retirement benefits to railway servants and their families. The rules recognize various categories of railway employees and establish specific criteria for pension eligibility.

Rule 75 of the Railway Services (Pension) Rules, 1993 specifically addresses family pension entitlements. According to this rule, “In the event of death in harness of a railway servant who had completed one year of continuous service, the family of the deceased shall be entitled to family pension.” This provision establishes the fundamental principle that families of railway employees who die while in service are entitled to pension benefits, subject to certain qualifying conditions.

The rules also distinguish between different categories of railway employees, including permanent employees, temporary employees, and substitute employees. Each category has specific provisions governing their pension rights, with the underlying principle being to provide social security and uphold the family pension rights of railway employees who have served the railways with dedication and commitment.

Indian Railway Establishment Manual

The Indian Railway Establishment Manual [3] provides detailed guidelines for the administration of railway personnel policies. Rule 1515 of this manual specifically addresses the rights and privileges of substitute employees. It states that “Substitutes should be afforded all the rights and privileges as may be admissible to temporary railway servants, from time to time on completion of four months continuous service.”

This provision is crucial as it establishes the principle of parity between substitute employees and temporary railway servants. The manual recognizes that substitute employees, despite their nomenclature, perform the same duties and responsibilities as regular employees and therefore deserve similar treatment in terms of benefits and privileges.

The manual also outlines the screening and regularization process for substitute employees, emphasizing that those who successfully complete the prescribed screening procedures and demonstrate satisfactory performance should be considered for regularization. This process ensures that deserving substitute employees are not discriminated against merely due to their initial appointment status.

Case Background and Factual Matrix

The Appellant’s Circumstances

Mala Devi, the appellant in this case, was the widow of a substitute Porter who was appointed by the Indian Railways in 1986. Her husband was subsequently posted as a Guard/Shuntman at Garhara station after undergoing the mandatory medical screening process. The deceased employee served diligently for more than nine years and eight months before passing away while in service in 1996.

The significance of the deceased employee’s service cannot be understated. He had successfully completed the initial screening process, which included medical fitness tests and performance evaluations. His appointment as a Guard/Shuntman, a position of responsibility within the railway system, demonstrates that he was a trusted and capable employee who contributed meaningfully to railway operations.

Following her husband’s death, Mala Devi was appointed as a Substitute Gangman on compassionate grounds, which itself is a recognition of her husband’s service and her family’s contribution to the railway system. She was later regularized in this position, indicating that the railway administration recognized her capability and the legitimacy of her family’s connection to the railway service.

Administrative Rejection and Legal Challenges

Despite her husband’s substantial service and her own subsequent employment with the railways, Mala Devi’s application for family pension was rejected by the railway administration. The rejection was based on two primary grounds: first, that her husband had not completed the mandatory ten-year qualifying service period, falling short by approximately three months; and second, that he was never formally regularized during his lifetime.

This rejection led to a prolonged legal battle that spanned multiple judicial forums. The Central Administrative Tribunal, Patna Bench, initially dismissed her application in 2015, upholding the railway administration’s decision. The tribunal’s reasoning was primarily technical, focusing on the strict interpretation of service rules without considering the broader principles of social justice and equity.

The Patna High Court subsequently upheld the tribunal’s decision in 2016, further complicating Mala Devi’s quest for justice. The High Court’s decision reflected a narrow interpretation of the pension rules, emphasizing literal compliance with service requirements rather than considering the substantive contribution of the deceased employee.

Supreme Court’s Legal Analysis

Interpretation of Rule 75

The Supreme Court’s analysis began with a detailed examination of Rule 75 of the Railway Services (Pension) Rules, 1993. The Court emphasized that this provision clearly states a temporary railway servant becomes eligible for family pension after completing just one year of continuous service. This interpretation is crucial, as it affirms that the ten-year qualifying service often cited by administrative authorities does not apply uniformly to all categories of employees. In doing so, the Court reinforced the legal foundation for safeguarding the family pension rights of railway employees, particularly those in temporary or substitute roles.

The court’s interpretation reflects a purposive approach to statutory construction, where the intent and spirit of the legislation are given precedence over rigid literal interpretation. The judges recognized that the rule was designed to provide social security to families of railway employees who had made meaningful contributions to the railway system, regardless of their formal employment status.

Assessment of Substitute Employee Rights

The Supreme Court carefully examined the status of substitute employees within the railway system. The court noted that Rule 18(3) of the Pension Rules specifically addresses the treatment of substitute employees, equating them with temporary railway servants for pension purposes. This provision ensures that substitute employees are not discriminated against merely because of their initial appointment category.

The court emphasized that the deceased employee had successfully completed the screening process and had been performing his duties satisfactorily for over nine years. This performance record, combined with his successful completion of medical fitness tests and assignment to a responsible position, demonstrated that he was effectively functioning as a regular railway employee despite his technical classification as a substitute.

Critique of Administrative Approach

The Supreme Court strongly criticized the railway administration’s approach to denying pension benefits. The court observed that “the denial of family pension from her deceased husband for not completing 10 years of qualifying service by falling short of hardly 3 months, is not in congruence with the legislative intent of the Indian Railway Establishment Manual & the Railway Pension Rules, 1993.”

This criticism highlights the court’s concern with the mechanical application of rules without considering the underlying principles of social justice and equity. The court emphasized that the deceased employee’s service of over nine years and eight months represented a substantial contribution to the railway system, and denying pension benefits for a shortfall of three months defeated the very purpose of social welfare legislation.

Judicial Reasoning and Legal Principles

Social Welfare Legislation Interpretation

The Supreme Court’s judgment reflects a broader philosophy regarding the interpretation of social welfare legislation. The court emphasized that such legislation should be interpreted liberally to achieve its intended social objectives. The judges noted that “the salutary purpose of the rules thereunder is to extend the benefit of family pension to the families of those servants who have served for a considerable strength of time.”

This approach aligns with established jurisprudence that recognizes social welfare legislation as remedial in nature, designed to protect vulnerable sections of society. The court’s emphasis on the “salutary purpose” of pension rules underscores the importance of considering the broader social objectives of such legislation rather than focusing solely on technical compliance.

Substantive Justice Over Procedural Formalities

The judgment demonstrates the Supreme Court’s commitment to substantive justice over procedural formalities. The court recognized that while the deceased employee may not have been formally regularized, he had effectively performed the duties of a regular railway employee for an extended period. The court noted that “it is an admitted factum that the deceased had reached the necessary stage of scrutiny/screening for regularization of the post, and had been carrying out his services, literally till his last breath.”

This approach reflects the court’s understanding that justice should not be sacrificed at the altar of technical procedural requirements. The emphasis on the deceased employee’s continuous service and satisfactory performance highlights the court’s focus on substantive contribution rather than formal categorization.

Critique of Narrow Interpretation

The Supreme Court specifically criticized the narrow interpretation adopted by lower courts and administrative authorities. The court observed that such a narrow approach “defeats the spirit of social welfare legislation” and fails to achieve the intended objectives of pension rules. The judges emphasized that the employee, having served with the Railways for a substantial period before dying in harness, could not be excluded from posthumous benefits merely due to technical deficiencies in his service record.

This critique reflects the court’s broader concern with the tendency of administrative authorities to adopt overly restrictive interpretations of beneficial legislation. The court’s emphasis on the “spirit of social welfare legislation” underscores the importance of considering the broader social objectives of such laws rather than focusing solely on technical compliance.

Regulatory Framework and Implementation

Pension Administration Mechanism

The administration of railway pension benefits involves multiple layers of authority and oversight. The Railway Board, as the apex body, issues guidelines and clarifications regarding pension policies. These guidelines are then implemented by various railway zones and divisions through their respective pension disbursing agencies.

The current system requires pension cases to be processed through the concerned railway administration, which verifies service records, calculates pension amounts, and ensures compliance with applicable rules. However, the complexity of this system often leads to delays and disputes, particularly in cases involving temporary or substitute employees whose service records may be incomplete or ambiguous.

Challenges in Implementation

The implementation of pension rules faces several challenges, particularly in cases involving temporary or substitute employees. Service records for such employees may be incomplete or scattered across different administrative units. The lack of standardized procedures for verifying service periods and determining eligibility often leads to inconsistent decisions and prolonged disputes.

The Supreme Court’s judgment in Mala Devi’s case highlights the need for more streamlined and equitable procedures for processing pension claims. The court’s emphasis on substantive justice over procedural formalities suggests that administrative authorities should adopt a more flexible approach to pension administration, particularly in cases involving long-serving employees who may have been affected by administrative inefficiencies.

Implications and Future Directions

Impact on Railway Employee Rights

The Supreme Court’s judgment has significant implications for the rights of railway employees and their families. The decision establishes important precedents regarding the treatment of substitute and temporary employees, ensuring that they receive equitable treatment in pension matters. The court’s emphasis on the one-year qualifying service requirement for temporary employees, as opposed to the ten-year requirement for permanent employees, provides clarity and protection for vulnerable categories of railway workers.

The judgment also reinforces the principle that social welfare legislation should be interpreted liberally to achieve its intended objectives. This approach is likely to influence future cases involving pension disputes and may encourage administrative authorities to adopt more equitable approaches to benefit administration.

Administrative Reforms

The judgment suggests the need for comprehensive administrative reforms in pension administration. Railway authorities should review existing procedures to ensure that they align with the Supreme Court’s interpretation of pension rules. This may involve updating administrative guidelines, training personnel on the proper interpretation of social welfare legislation, and establishing more streamlined procedures for processing pension claims.

The court’s criticism of the narrow interpretation adopted by administrative authorities also suggests the need for greater sensitivity to the social objectives of pension legislation. Training programs for administrative personnel should emphasize the importance of considering the broader social context of pension rules rather than focusing solely on technical compliance.

Conclusion

The Supreme Court’s judgment in Mala Devi v. Union of India represents a significant milestone in the protection of family pension rights of railway employees. The decision demonstrates the court’s commitment to substantive justice and its willingness to interpret social welfare legislation in a manner that achieves its intended objectives. The judgment provides important guidance for administrative authorities and establishes clear principles for the treatment of temporary and substitute railway employees.

The case also highlights the ongoing challenges faced by families of railway employees in securing their rightful pension benefits. The court’s award of ex gratia compensation to Mala Devi recognizes the hardship caused by prolonged litigation and administrative delays. This aspect of the judgment serves as a reminder to administrative authorities of their responsibility to process pension claims efficiently and equitably.

The judgment’s emphasis on the “spirit of social welfare legislation” provides a framework for future cases involving pension disputes. It encourages a more holistic approach to benefit administration that considers the broader social objectives of such legislation rather than focusing solely on technical compliance. This approach is likely to benefit numerous railway employees and their families who have faced similar challenges in asserting their family pension rights.

References

[1] Mala Devi v. Union of India & Ors., 2025 INSC 855, Supreme Court of India.

[2] Railway Services (Pension) Rules, 1993, Ministry of Railways, Government of India. Available at: https://railwayrule.com/the-railway-services-pension-rules-1993 

[3] Indian Railway Establishment Manual, Railway Board, Ministry of Railways. Available at: https://indianrailwayemployee.com/content/indian-railways-establishment-manual-irem 

[4] Railway Services (Pension) Second Amendment Rules, 2024, Ministry of Railways. Available at: https://www.gconnect.in/orders-in-brief/railways-orders-in-brief/railway-services-pension-second-amendment-rules-2024-invalid-pension.html 

[5] Supreme Court of India Official Website. Available at: https://www.sci.gov.in/ 

[6] AdvocateKhoj Legal Database, Supreme Court Judgments. Available at: https://www.advocatekhoj.com/library/judgments/announcement.php 

Edited and Authorized by Vishal Davda

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