Supervisory Role and Salary Define Status: High Court Clarifies 'Workman' Exclusion in Labor Disputes

The High Court dismissed the petition challenging the Industrial Tribunal's ruling that excluded the petitioner from protection under the Industrial Disputes Act due to his supervisory role and salary.

The Punjab and Haryana High Court has dismissed a petition challenging an Industrial Tribunal’s decision that denied the petitioner relief under the Industrial Disputes Act (ID Act). The court confirmed that the petitioner, who served as a Store Manager, does not qualify as a "workman" under Section 2(s) of the ID Act due to his supervisory duties and substantial salary. The ruling underscores the exclusion of managerial and supervisory roles from the protections typically afforded to workmen under labor laws.

The petitioner, Baldev Singh, joined the respondent company as a Store-Keeper/Manager on February 14, 2012. On February 4, 2017, his employment was terminated, prompting him to seek relief through the Industrial Tribunal. The Tribunal, however, ruled against him on April 22, 2022, determining that he did not meet the criteria to be classified as a "workman" under the ID Act. The petitioner subsequently challenged this decision before the High Court, seeking to overturn the Tribunal’s ruling.

The High Court, presided over by Justice Jagmohan Bansal, upheld the Industrial Tribunal’s findings, which were primarily based on the petitioner’s admission during cross-examination. It was revealed that the petitioner had been performing supervisory duties over three other employees and was using the company’s official email as a Store Manager. Additionally, he was receiving a salary of ₹48,500 per month at the time of his termination.

The Tribunal noted, "The workman was not only performing supervisory duties but also receiving a salary well above the statutory threshold, which excludes him from the definition of 'workman' under Section 2(s) of the ID Act."

The court emphasized the statutory exclusions outlined in Section 2(s) of the ID Act, which explicitly excludes individuals employed in a managerial or supervisory capacity, especially those drawing wages exceeding ₹10,000 per month. The petitioner’s role and remuneration clearly placed him outside the purview of this definition. Consequently, the High Court found no infirmity in the Tribunal’s decision and dismissed the petition.

The High Court's ruling reinforces the clear statutory boundaries that differentiate managerial and supervisory staff from "workmen" under the ID Act. By affirming the Industrial Tribunal's decision, the court has highlighted the importance of role and salary in determining eligibility for protections under labor laws. This judgment serves as a significant precedent, reiterating that employees in managerial positions with substantial supervisory responsibilities and higher salaries are not entitled to the protections meant for workmen under the ID Act.

Date of Decision: July 29, 2024