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Issues Involved:
1. Whether the petitioner-employer was given an opportunity to lead evidence in support of disciplinary action after the Labour Court found the Enquiry Officer's findings to be perverse. 2. Whether the Labour Court's denial of the opportunity to lead evidence constituted an improper exercise of jurisdiction. 3. Interpretation of pleadings regarding the employer's right to lead evidence if the domestic enquiry was found to be vitiated. 4. The necessity of framing issues related to the validity and legality of the domestic enquiry. 5. The impact of the Labour Court's procedural conduct on the employer's right to a fair trial. Detailed Analysis: 1. Opportunity to Lead Evidence: The petitioner-employer contended that they were not given an opportunity to lead evidence in support of the disciplinary action after the Labour Court held that the findings of the Enquiry Officer were perverse. The Labour Court had initially held that the inquiry was conducted fairly and properly, but upon further evidence, it found the findings perverse and the punishment disproportionate. The employer argued that, based on precedents, they should have been allowed to present evidence to substantiate the charges and the disciplinary action. 2. Improper Exercise of Jurisdiction: The petitioner argued that the Labour Court acted in improper exercise of jurisdiction by not allowing them to lead evidence after determining the enquiry findings were perverse. They relied on Supreme Court decisions in Karnataka State Road Transport Corporation v. Lakshmidevamma and Bharat Forge Company Ltd. v. A. B. Zodge, which established that employers have the right to present evidence if the disciplinary action is found vitiated. 3. Interpretation of Pleadings: The respondent argued that the petitioner did not specifically request to lead evidence in case the findings were held perverse, both in their written statement and during arguments. The court, however, found that the petitioner's pleadings did imply a request to lead evidence if the enquiry was found to breach principles of natural justice or otherwise, and thus, the Labour Court should have recognized this implicit request. 4. Framing Issues: The court noted that it is primarily the duty of the Labour Court to frame issues based on the pleadings. The absence of a specific prayer for framing issues does not absolve the court from its duty. The court should have framed issues regarding whether the findings of the Enquiry Officer were perverse alongside the issue of whether the enquiry complied with principles of natural justice. 5. Procedural Conduct and Fair Trial: The court highlighted that the Labour Court's failure to provide an opportunity to the employer to lead evidence after declaring the enquiry findings perverse resulted in prejudice against the petitioner. The court emphasized that the employer's right to adduce evidence should be upheld once the enquiry findings are deemed perverse, as per the established legal principles. Conclusion: The petitions were successful. The impugned orders were quashed and set aside to the extent they went beyond the Labour Court's decision on the perversity of the Enquiry Officer's findings. The matter was remanded to the Labour Court to allow the petitioner to lead evidence in support of the charges and punishment imposed. The Labour Court was directed to expedite the hearing and dispose of the matter by March 31, 2002, without expressing any opinion on the merits of the case. Rule was made absolute with no order as to costs.
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