The Supreme Court in Regional Director, Employees’ State Insurance Corporation Vs. High Land Coffee Works of P.F.X. Saldanha and Sons and Another, examined the word ‘include’ employed in Section 2(12) of Employees State Insurance Act and held as follows (at P. 131 of AIR):

The word ‘include’ in the statutory definition is generally used to enlarge the meaning of the preceding words and it is by way of extension, and not with restriction. The word ‘include’ is very generally used in interpretation clauses in order to enlarge the meaning of words or phrases occurring in the body of the statute, and when it is so used, these words or phrases must be construed as comprehending, not only such things as they signify according to their natural import but also those things which the interpretation clause declares that they shall include.