The concept of bonus has received the attention of this Court in a series of cases, and we need mention only some of the. One of the first authoritative decisions rendered by this Court is Muir Mill Co. Ltd. v. Suti Mill, [1955] 1 S.C.R. 991, where N. H. Bhagwati, J. speaking for the Court, analysed the concept of bonus and described it as representing the cash incentive paid in addition to wages and given conditionally on certain standards of attendance and efficiency being attained. When wages fall short of the living standard or the industry makes huge profits profits part of which are due to the contribution 645 Which the workmen make in increasing production, the demand for bonus, it was said, becomes an industrial claim. The view was followed by this Court in the Shri Meenakahi Mills, Ltd. v. Their Workmen, [1958] S.C.R. 878, but the two conditions, that the wages paid to workmen fall short of living wages and that the industry should be shown to have wade profits which are partly the result of the contribution made by the workmen in increasing production were regarded as being of cumulative significance. Then followed Standard Vacuum Refining Co. of India v. Its Workmen and Ant.,[1961] 3 S.C.R. 536, which dealt with the concept of bonus elaborately while re-affirming what had been said in the earlier two cases. It has not been shown to us that this Court has subsequently widened the concept of bonus to include a payment made by the employer ex-gratia or as an expression of goodwill towards its employees. It seems to us clear that the first category of remuneration falling within the definition of "wages" in sub-s.(22) of 8. 2 of the Employees' State Insurance Act, 1948 is not satisfied by the bonus in question in these appeals.