High Court Cannot Reassess Labour Court's Findings Like an Appellate Body: Delhi HC

In a significant ruling, the Delhi High Court upheld the Labour Court’s award of ₹5,00,000 in compensation to a bus driver who was wrongfully terminated by his employer, M/s Mohan Brothers. Justice Girish Kathpalia, dismissing the employer’s writ petition, reiterated that High Courts, while exercising jurisdiction under Article 226 of the Constitution, cannot function as appellate bodies to reappreciate evidence, unless the findings are perverse or arbitrary. Citing State of Rajasthan v. Bhupendra Singh, 2024 SCC OnLine SC 1908, the Court emphasized: "Findings of fact by the Labour Court, if based on some evidence, cannot be disturbed unless they are perverse or arbitrary."

"Employer’s Claim of Voluntary Resignation is Baseless—Labour Inspector’s Report Exposes Falsehood"

The petitioner, M/s Mohan Brothers, contended that the employee, Mr. Mithilesh Pandey, had voluntarily abandoned employment after receiving a full and final settlement of ₹30,000. However, the Court found no proof of such a settlement.

Instead, the Labour Inspector’s report dated 04.12.2012 clearly established that the employer had refused to reinstate the worker, contradicting the employer’s claims of abandonment. Justice Kathpalia held:

"If the worker had truly accepted full and final settlement, why did the employer fail to disclose this to the Labour Inspector who visited their premises? The alleged settlement voucher appears to be a fabricated document."

"Employer’s Attempt to Avoid Compensation Fails—Worker’s Subsequent Job Does Not Affect Entitlement"

The petitioner argued that since the worker later took up another job, he was not entitled to compensation. However, the Court rejected this contention, stating that an illegally terminated worker cannot be expected to starve while awaiting justice.

"One cannot expect a workman to sit idle and suffer only to preserve his legal rights. Taking another job does not erase the fact that his termination was illegal," the Court observed.

"Reinstatement Not Feasible, Compensation Instead of Reinstatement Justified"
While the Labour Court found the termination illegal, it held that reinstatement was impractical since the worker had since taken up other employment. Instead, a compensation of ₹5,00,000 was awarded, a decision the High Court fully endorsed.

"The Labour Court rightly awarded compensation in lieu of reinstatement, considering the circumstances. This Court finds no ground to interfere," ruled Justice Kathpalia.

"High Court Cannot Function as an Appellate Court in Labour Matters—Writ Petition Dismissed with Costs"

Reiterating that Article 226 does not permit the High Court to reappreciate evidence like an appellate body, the Court stated:

"The Labour Court is the sole judge of facts. This Court cannot review the adequacy or reliability of evidence unless there is a manifest error or perversity."

Accordingly, the High Court dismissed the writ petition and directed the employer to pay ₹25,000 as costs to the worker within a week for litigation expenses.

This ruling reinforces the limited scope of judicial review in labour disputes under Article 226, affirming that High Courts cannot reexamine evidence unless findings are perverse. It also highlights that employers cannot evade liability by fabricating settlement claims and that workers remain entitled to compensation even if they secure alternative employment post-termination.
 

Date of Decision: 13/02/2025