EOBI pension claim

My cousin had died around 20 days ago. He was serving in an NGO on project based position against which his NGO was paying monthly EOBI contribution for him for the total period of 2 years and 6 months till his death. However, as per EOBI officials, EOBI pension claims require atleast 3 years of continuous service. My cousin had worked on daily wages earlier than this job with this and some other NGOs but they did not pay his EOBI contribution since he was a daily wager. You are requested to please guide whether he can avail pension from EOBI and is there any similar court order in history.