1984 (5) TMI 266 - SC - Indian Laws

Summary

Issues Involved:
1. Validity of Domestic Enquiry and Dismissal Orders.
2. Jurisdiction of Labour Court and Industrial Court under the Madhya Pradesh Industrial Relations Act, 1950.
3. High Court's Exercise of Jurisdiction under Articles 226 and 227 of the Constitution.

Summary:

1. Validity of Domestic Enquiry and Dismissal Orders:
The appellants, workmen of the respondent company, were dismissed following a domestic enquiry based on allegations of assaulting a fellow worker, Verma. The Labour Court upheld the enquiry and dismissal. However, the Industrial Court found the enquiry biased and unfair, setting aside the Labour Court's decision and remanding the matter for fresh consideration.

2. Jurisdiction of Labour Court and Industrial Court under the Madhya Pradesh Industrial Relations Act, 1950:
The Labour Court's jurisdiction under Sec. 61 includes examining the "propriety or legality" of employer actions under the standing orders. The Industrial Court, under Sec. 66, can revise Labour Court decisions if there is a jurisdictional error or material irregularity. The Supreme Court emphasized that "propriety" allows the Labour Court to reach different conclusions on the same facts, and the Industrial Court can intervene if the Labour Court fails to exercise its jurisdiction properly.

3. High Court's Exercise of Jurisdiction under Articles 226 and 227 of the Constitution:
The High Court quashed the Industrial Court's decision, stating it exceeded its jurisdiction by interfering with factual findings. The Supreme Court held that the High Court misinterpreted the scope of the Labour Court's jurisdiction, which includes examining both the legality and propriety of orders. The High Court's interference was deemed unjustified, as the Industrial Court's remand order was within its jurisdiction and aimed at ensuring justice.

Conclusion:
The Supreme Court allowed the appeals, set aside the High Court's decision, and restored the Industrial Court's order. The Labour Court was directed to prioritize and dispose of the matter within six months. Appeals allowed.