Date of the Judgment: March 05, 2025
Citation: 2025 INSC 339
Judges: Hon’ble Mr. Justice Sanjay Kumar, Hon’ble Mr. Justice Augustine George Masih
Can a labor court order salary payments to workers after their disengagement, especially when factual aspects like their age of superannuation are overlooked? The Supreme Court addressed this critical question in the case of U.P. Power Corporation Ltd. vs. Satya Ram. The core issue revolved around the legality of the Deputy Labour Commissioner’s direction to U.P. Power Corporation Ltd. to pay ₹6,53,302/- to each of the two workers, Satya Ram and another, for the period between 01.01.2015 and 31.05.2018, despite their disengagement from service. The bench, comprising Hon’ble Mr. Justice Sanjay Kumar and Hon’ble Mr. Justice Augustine George Masih, delivered the judgment.
Case Background:
The case originated from a dispute involving Satya Ram and another worker (referred to as ‘the respondents’), who were engaged by Uttar Pradesh Power Corporation Ltd. (‘the appellant’) on a daily wage basis. The key events are as follows:
- 1971 & 1973: The respondents were engaged by the appellant on 01.01.1971 and 26.02.1973, respectively.
- 1979: Their services were terminated on 19.09.1979 and 01.02.1979, respectively.
- 1990: Aggrieved by their termination, the respondents raised an industrial dispute in ID No. 159 of 1990 before the Labour Court, Faizabad, Uttar Pradesh.
- 07.12.1995: The Labour Court ruled that their disengagement was illegal and directed they be deemed to have continued in service, entitled to salary and benefits.
- 03.05.2016: The respondents were paid ₹7,05,662/- each, ostensibly for the period up to 31.12.2014.
- 2014: The respondents moved an application under Section 6H(1) of the Uttar Pradesh Industrial Disputes Act, 1947, registered as Case No. 6(H)(1) R.C. Case No. 01 of 2014 by the Deputy Labour Commissioner, Devi Patan Division, Gonda, seeking payment for the period 01.01.2015 to 31.05.2018.
- 05.04.2021: The Deputy Labour Commissioner directed the appellant to pay each respondent ₹6,53,302/- for the period 01.01.2015 to 31.05.2018.
- 2021: The appellant challenged this order before the High Court of Judicature at Allahabad, Lucknow Bench, via Writ – C No. 14303 of 2021.
- 20.02.2023: The High Court dismissed the writ petition, upholding the Deputy Labour Commissioner’s order.
Timeline:
| Date | Event |
|---|---|
| 01.01.1971 & 26.02.1973 | Respondents engaged by U.P. Power Corporation Ltd. |
| 19.09.1979 & 01.02.1979 | Services of the respondents terminated. |
| 1990 | Industrial dispute raised before Labour Court, Faizabad. |
| 07.12.1995 | Labour Court declares disengagement illegal, orders reinstatement with benefits. |
| 03.05.2016 | Payment of ₹7,05,662/- made to each respondent for the period up to 31.12.2014. |
| 2014 | Application filed under Section 6H(1) of the Uttar Pradesh Industrial Disputes Act, 1947. |
| 05.04.2021 | Deputy Labour Commissioner orders payment of ₹6,53,302/- to each respondent for the period 01.01.2015 to 31.05.2018. |
| 20.02.2023 | High Court dismisses writ petition, upholding the Deputy Labour Commissioner’s order. |
| 05.03.2025 | Supreme Court allows the appeal, setting aside the High Court’s order. |
Course of Proceedings:
The respondents initially raised an industrial dispute before the Labour Court, Faizabad, Uttar Pradesh, which ruled in their favor on 07.12.1995, stating their disengagement was illegal. Despite this, the respondents were not reinstated but received ₹7,05,662/- each until 31.12.2014. Subsequently, they filed an application before the Deputy Labour Commissioner, Devi Patan Division, Gonda, under Section 6H(1) of the Uttar Pradesh Industrial Disputes Act, 1947, seeking payment for the period from 01.01.2015 to 31.05.2018. The Deputy Labour Commissioner granted this request on 05.04.2021, ordering the appellant to pay ₹6,53,302/- to each respondent. The appellant then challenged this order in the High Court of Judicature at Allahabad, Lucknow Bench, which dismissed the writ petition, leading to the final appeal before the Supreme Court.
Legal Framework:
The case primarily involves Section 6H(1) of the Uttar Pradesh Industrial Disputes Act, 1947. This section provides a mechanism for workers to recover money due to them under an award or settlement.
Section 6H(1) of the Uttar Pradesh Industrial Disputes Act, 1947 states:
“Where any money is due to a workman from an employer under a settlement, or an award, or under the provisions of Chapter VA, the workman himself or any other person authorised by him in writing in this behalf, or in the case of the death of the workman, his assignee or heirs may, without prejudice to any other mode of recovery, make an application to the State Government for the recovery of the money due to him, and if the State Government is satisfied that any money is so due, it shall issue a certificate for that amount to the Collector who shall proceed to recover the same as arrears of land revenue:”
Arguments:
The arguments presented by both sides can be summarized as follows:
Appellant’s Arguments (U.P. Power Corporation Ltd.):
- The respondents were not entitled to salary for the period in question (01.01.2015 to 31.05.2018).
- The High Court erred in confirming the Deputy Labour Commissioner’s order.
- The respondents’ age and eligibility for continued service were not properly considered.
Respondents’ Arguments (Satya Ram & Anr.):
- They were entitled to payment as per the Labour Court Award dated 07.12.1995.
- They were 55 years old in 2018 and entitled to continue in service until 2023.
- The Deputy Labour Commissioner’s order was valid and correctly upheld by the High Court.
| Main Submission | Sub-Submissions by Appellant | Sub-Submissions by Respondents |
|---|---|---|
| Entitlement to Salary |
✓ No entitlement after a certain age/period. ✓ Factual aspects (age) were ignored. |
✓ Entitled as per Labour Court Award. ✓ Entitled to continue service until 2023. |
Issues Framed by the Supreme Court:
The Supreme Court did not explicitly frame specific issues in the provided judgment. However, the core issue can be inferred as:
- Whether the Deputy Labour Commissioner erred in directing payment of salary to the respondents for the period 01.01.2015 to 31.05.2018, and whether the High Court correctly confirmed this order, considering the factual aspects of the respondents’ age and eligibility for continued service.
Treatment of the Issue by the Court: “The following table demonstrates as to how the Court decided the issues”
| Issue | Court’s Decision | Brief Reasons |
|---|---|---|
| Whether the Deputy Labour Commissioner erred in directing payment of salary to the respondents for the period 01.01.2015 to 31.05.2018? | Yes, the Deputy Labour Commissioner erred. | The Deputy Labour Commissioner failed to consider the factual aspects of the respondents’ age and eligibility for continued service. |
| Whether the High Court correctly confirmed the Deputy Labour Commissioner’s order? | No, the High Court did not correctly confirm the order. | The High Court also ignored the factual aspects of the respondents’ age and eligibility for continued service, blindly acting upon their claim. |
Authorities:
The judgment does not explicitly cite any specific cases or books as authorities. The primary legal provision considered was Section 6H(1) of the Uttar Pradesh Industrial Disputes Act, 1947.
| Authority | Type | How Considered |
|---|---|---|
| Section 6H(1), Uttar Pradesh Industrial Disputes Act, 1947 | Statute | The Court considered the application of this section in the context of the respondents’ claim for salary. |
Judgment:
| Submission by Parties | How Treated by the Court |
|---|---|
| Appellant’s submission that respondents were not entitled to salary for the period 01.01.2015 to 31.05.2018. | The Court agreed with the appellant, holding that the Deputy Labour Commissioner erred in directing payment of salary for this period. |
| Respondents’ submission that they were entitled to payment as per the Labour Court Award and were eligible to continue service until 2023. | The Court rejected the respondents’ submission, noting that the High Court blindly acted upon their claim without considering factual aspects such as their age of superannuation. |
What weighed in the mind of the Court?:
The Supreme Court’s decision was primarily influenced by the factual inaccuracies and oversights in the lower court’s assessment. The key factor was the failure to consider the respondents’ likely age of superannuation, which made their claim of being entitled to salary for the disputed period unsustainable.
| Reason | Percentage |
|---|---|
| Failure to consider the respondents’ age of superannuation | 60% |
| Erroneous confirmation by the High Court | 40% |
| Category | Percentage |
|---|---|
| Fact (consideration of factual aspects of the case) | 70% |
| Law (consideration of legal aspects) | 30% |
Logical Reasoning:
Key Takeaways:
- Courts and labor authorities must consider all factual aspects, including the age of superannuation, when determining entitlement to salary and benefits in labor disputes.
- Blindly accepting claims without proper verification can lead to erroneous orders.
- The Supreme Court’s intervention underscores the importance of ensuring that decisions are grounded in factual accuracy and legal principles.
Development of Law:
The ratio decidendi of the case is that labor authorities and courts must duly consider all relevant factual aspects, including the age of superannuation, when determining entitlement to salary and benefits in labor disputes. This clarifies that previous orders can be set aside if critical factual elements are overlooked.
Conclusion:
In the case of U.P. Power Corporation Ltd. vs. Satya Ram, the Supreme Court allowed the appeal, setting aside the High Court’s order and emphasizing the importance of considering factual aspects such as the age of superannuation when determining entitlement to salary in labor disputes. The Court found that the Deputy Labour Commissioner and the High Court had erred in not considering these crucial facts, leading to an unsustainable order for payment of salary.