As per case facts, Ex-employees of Steel Authority of India (SAIL) did not vacate allotted staff quarters post-retirement. SAIL withheld gratuity due to non-vacation and sought penal rent. Ex-employees challenged ... eviction notices and sought release of gratuity with interest, arguing against penal rent. Lower courts relied on a previous order which treated the issue as an equitable concession to an employee, allowing only normal rent adjustment. SAIL appealed, relying on a later Supreme Court order that clarified penal rent could be adjusted from gratuity. The question arose whether reliance on the previous order as a binding precedent was sustainable, and whether SAIL could adjust penal rent from gratuity for staff quarters retained beyond the permissible period. Finally, the Supreme Court ruled that the previous order was a concession based on specific facts, not a binding precedent, and affirmed that if an employee occupies a quarter beyond the specified period, penal rent is a natural consequence adjustable from gratuity. It held that obligations are mutual: ex-employees must vacate, and management must release gratuity after permissible deductions. No interest is payable on withheld gratuity during unauthorized occupation. Considering the ex-employees' background and the policy's timing, the Court fixed a reasonable penal rent of Rs. 1000 per month for the present batch, while emphasizing this fixation is not a precedent, and allowed the appeals.