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Issues Involved:
1. Jurisdiction of Civil Court in employment termination disputes. 2. Applicability of Industrial Disputes Act. 3. Competence of authority in passing termination orders. Issue-wise Detailed Analysis: 1. Jurisdiction of Civil Court in Employment Termination Disputes: The primary issue revolves around whether the Civil Court has jurisdiction to entertain suits filed by workmen challenging their dismissal or removal from service. The City Civil Court initially concluded that it lacked jurisdiction, leading to the dismissal of the suits. The Single Judge of the Gujarat High Court, however, opined that the Civil Court could examine the competence of the authority passing the termination orders but not the procedural irregularities in the disciplinary inquiry, which are governed by Standing Orders. The Division Bench of the High Court later upheld the City Civil Court's decision, asserting that the Labour Court or Industrial Tribunal should handle such disputes, thus implying the Civil Court's jurisdiction is barred. 2. Applicability of Industrial Disputes Act: The Supreme Court examined whether the relief sought by the plaintiffs falls within the ambit of an industrial dispute under the Industrial Disputes Act. It referenced the case of Dhulabhai and Ors. v. The State of Madhya Pradesh and Anr., which established that exclusion of Civil Court jurisdiction is not readily inferred unless the statute provides finality to the orders of the special tribunal and offers adequate remedies. The Court emphasized that the Industrial Disputes Act was designed to provide a speedy, inexpensive, and effective forum for resolving disputes between workmen and employers, which Civil Courts, with their lengthy procedures, cannot efficiently handle. 3. Competence of Authority in Passing Termination Orders: The Single Judge had initially remitted the matter to the City Civil Court to determine whether the termination orders could be interfered with due to a lack of competence by the authority issuing them. However, the Division Bench disagreed, stating that even the question of the authority's competence should be addressed by the Labour Court or Industrial Tribunal. The Supreme Court reaffirmed this stance, indicating that disputes involving the recognition, observance, or enforcement of rights and obligations under the Industrial Disputes Act or related enactments should be resolved by the forums created under the Act. Conclusion: The Supreme Court concluded that the jurisdiction of the Civil Court is impliedly barred in cases involving employment termination disputes that fall under the Industrial Disputes Act. The appropriate forum for resolving such disputes is the Labour Court or Industrial Tribunal. The appeals were dismissed, with the observation that the workmen could approach the appropriate industrial forum for resolution.
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