Supreme Court Upholds Amendment Transferring Labour Law Offenses to Criminal Courts: State of M.P. vs. M.P. Transport Workers Fedn. (29 January 2020)

Introduction

Date of the Judgment: 29 January 2020

Citation: Civil Appeal No. 4658 of 2009, with C.A. No. 7613 of 2009

Judges: Hon’ble Mr. Justice Sanjay Kishan Kaul and Hon’ble Mr. Justice K.M. Joseph

Can the government change the court that hears cases about labor law violations? The Supreme Court of India recently addressed this question in a case concerning the Madhya Pradesh Labour Laws (Amendment) and Misc. Provisions Act, 2002. The core issue was whether transferring the power to try these cases from Labour Courts to regular criminal courts was a violation of the Constitution. This decision impacts how labor law offenses are handled in Madhya Pradesh.

The judgment was delivered by a two-judge bench comprising Hon’ble Mr. Justice Sanjay Kishan Kaul and Hon’ble Mr. Justice K.M. Joseph. The opinion was authored by Hon’ble Mr. Justice Sanjay Kishan Kaul.

Case Background

The dispute began when the Labour Bar Association, Satna, and the M.P. Transport Workers Federation challenged the Madhya Pradesh Labour Laws (Amendment) and Misc. Provisions Act, 2002. This amendment, enforced on 5 August 2005, sought to move the trial of offenses under various labour laws from Labour Courts back to regular criminal courts.

Initially, until 1981, criminal courts handled these cases. The Madhya Pradesh Amendment Act No. 43 of 1981 then transferred this power to Labour Courts. The 2002 amendment aimed to reverse this, arguing that Labour Courts were overburdened and lacked the time to handle these criminal matters along with their existing caseload of industrial disputes.

The organizations challenging the amendment argued that assigning these cases to Labour Courts was intended to promote industrial harmony. They contended that this change was beneficial for workers and should not be reversed.

Timeline:

Course of Proceedings

The High Court struck down the 2002 Amendment primarily on the grounds that it violated Article 21 of the Constitution, which guarantees the right to speedy justice. The High Court reasoned that transferring cases back to criminal courts would delay the resolution of labour disputes.

The State of Madhya Pradesh appealed this decision to the Supreme Court. The Supreme Court issued a notice on 6 January 2009, and stayed the High Court’s order. On 20 July 2009, the Supreme Court granted leave and made the interim order absolute. This meant that the criminal courts continued to handle these cases for the next 11 years.

Legal Framework

The core legal issue revolves around the constitutional validity of the Madhya Pradesh Labour Laws (Amendment) and Misc. Provisions Act, 2002. The challenge was based on Article 14 and Article 21 of the Constitution of India.

Article 14 of the Constitution guarantees equality before the law and equal protection of the laws. The petitioners argued that the amendment was discriminatory and arbitrary.

Article 21 of the Constitution protects the right to life and personal liberty, which the High Court had interpreted to include the right to a speedy trial. The High Court held that by transferring cases to criminal courts, the amendment was violating this right.

Arguments

The arguments presented before the Supreme Court can be summarized as follows:

• Arguments against the Amendment (by the Labour Bar Association and M.P. Transport Workers Federation):
  • The transfer of cases to Labour Courts in 1981 was a deliberate measure to promote industrial harmony.
  • Shifting cases back to criminal courts would cause delays and undermine the goal of speedy justice in labour disputes.
  • The High Court’s decision was correct in holding that the amendment violated Article 21 of the Constitution by hindering the right to a speedy trial.
• Arguments in favor of the Amendment (by the State of Madhya Pradesh):
  • The Labour Courts are overburdened and unable to efficiently handle both industrial disputes and criminal cases under labour laws.
  • The regular criminal courts are better equipped to handle the criminal aspects of these cases.
  • The amendment was a matter of legislative policy to ensure efficient administration of justice.
  • There is no violation of any fundamental rights, and the legislature has the right to determine the appropriate forum for adjudication.

The State argued that the legislative competence to enact the amendment was not in question, and the only ground for challenge was whether it violated any fundamental rights. The State contended that the High Court had erred in interpreting Article 21 to strike down the amendment.

The Amicus Curiae, Mr. V. Giri, also assisted the Court, providing an objective perspective on the matter.

Submissions Table

Issues Framed by the Supreme Court

The Supreme Court did not explicitly frame issues in a separate section of the judgment. However, the core issue before the court was:

1. Whether the Madhya Pradesh Labour Laws (Amendment) and Misc. Provisions Act, 2002, which transferred the jurisdiction of trying offenses under labour laws from Labour Courts to regular criminal courts, is constitutionally valid.

Treatment of the Issue by the Court

The following table demonstrates as to how the Court decided the issues

Authorities

The Supreme Court relied on the following authorities:

Judgment

The Supreme Court allowed the appeals, setting aside the High Court’s order and upholding the validity of the Madhya Pradesh Labour Laws (Amendment) & Misc. Provisions Act, 2002.

How each submission made by the Parties was treated by the Court?

How each authority was viewed by the Court?

• Greater Bombay Co-operative Bank Ltd. v. United Yarn Tex (P) Ltd. (2007) 6 SCC 236*: The Court followed this authority to emphasize the limited scope of judicial review in matters of legislative competence and violation of fundamental rights.
• State of Andhra Pradesh & Ors. v. McDowell & Co. & Ors. (1996) 3 SCC 709*: The Court relied on this case to reiterate that it is not the court’s role to question the wisdom of the legislature.
• Mylapore Club v. State of Tamil Nadu (2005) 12 SCC 752*: This authority was used to support the view that it is the legislature’s prerogative to decide the appropriate method for providing expeditious justice.

What weighed in the mind of the Court?

The Supreme Court’s decision was influenced by several factors, primarily focusing on the separation of powers and the legislative prerogative. The Court emphasized that it is not the judiciary’s role to question the wisdom of the legislature unless there is a clear violation of constitutional principles. The Court also noted that the system of trying labour law offences in criminal courts had been functioning for over a decade without any significant grievances.

The Court’s reasoning was also influenced by the fact that the Labour Courts were already overburdened, and the transfer of these cases to criminal courts was a measure to ensure efficient administration of justice. The absence of any representation from the respondents further strengthened the Court’s view that the system was working adequately.

The Court’s decision reflects a deference to legislative judgment and a pragmatic approach to the administration of justice.

The Court stated, “It is not the function of this Court to test the wisdom of the Legislature and substitute its mind with the same.” This highlights the Court’s deference to the legislative process.

The Court also noted, “The process as evolved shows that the system, as it is, is working in the criminal Courts for the last more than a decade and no grievance has been made about the same.” This indicates the Court’s reliance on the practical functioning of the system.

Further, the Court observed, “It is for the Legislature to weigh this aspect as to what would be the appropriate method for providing expeditious justice to the common man.” This underscores the Court’s view that the legislature is best positioned to make such decisions.

Key Takeaways

• The Supreme Court upheld the Madhya Pradesh Labour Laws (Amendment) and Misc. Provisions Act, 2002, which transfers the jurisdiction of labour law offenses from Labour Courts to regular criminal courts.
• The Court emphasized the principle of separation of powers and the limited scope of judicial review in matters of legislative policy.
• The decision reinforces the idea that the legislature has the authority to determine the appropriate forum for adjudication, as long as it does not violate fundamental rights.
• The judgment highlights that the practical functioning of a system and the absence of grievances can be significant factors in judicial decision-making.
• The ruling implies that overburdened courts can be a valid reason for transferring cases to other courts, provided there is no violation of fundamental rights.

Directions

No specific directions were given by the Supreme Court in this judgment.

Specific Amendments Analysis

The judgment does not provide any specific analysis of any amendments.

Development of Law

The ratio decidendi of this case is that the judiciary should not interfere with legislative decisions regarding the appropriate forum for adjudication unless there is a clear violation of constitutional rights. This case reinforces the principle that the legislature has the power to determine the most efficient method for administering justice, and the courts should not substitute their own wisdom for that of the legislature. There is no change in the previous position of law.

Conclusion

In conclusion, the Supreme Court’s decision in State of M.P. vs. M.P. Transport Workers Fedn. upholds the legislative prerogative to determine the appropriate forum for trying offenses under labour laws. The Court emphasized that the judiciary should not question the wisdom of the legislature unless there is a clear violation of fundamental rights. The judgment reinforces the principle of separation of powers and provides clarity on the role of the judiciary in reviewing legislative decisions.