In a landmark decision emphasizing judicial restraint in interfering with labor tribunal awards, the Supreme Court restored the employment of Ganapati Bhikarao Naik, a former helper at Nuclear Power Corporation of India Limited (NPCIL). The judgment, delivered by a bench comprising Justice Hrishikesh Roy and Justice S.V.N. Bhatti, highlighted that factual findings of Labour Courts should not be disturbed without compelling reasons.
Background of the Case
The case revolved around the appointment of Ganapati Bhikarao Naik, whose employment was secured under a rehabilitation scheme for land-losers after land was acquired for the Kaiga Atomic Power Project. Naik, married to the daughter of a land-loser, Smt. Ganga, was granted a job certificate as her son-in-law in 1990. However, following estrangement and subsequent divorce, his father-in-law alleged that Naik misrepresented his marital status to fraudulently obtain the job. This led to an inquiry and Naik’s termination in 2002.
Naik sought legal recourse under the Industrial Disputes Act, 1947. The Central Government Industrial Tribunal (Labour Court) ruled in his favor in 2012, concluding that his appointment was lawful and ordering his reinstatement with full back wages. This decision was subsequently overturned by the Karnataka High Court’s Single Judge, prompting Naik to appeal to the Supreme Court.
Legal Issues Involved
1. Validity of Termination Based on Marital Status: The primary question was whether Naik’s termination, premised on his estranged marital relationship with the land-loser’s daughter, was justified under the terms of the rehabilitation scheme.
2. Extent of Judicial Interference: The case brought to light the broader issue of judicial restraint, particularly in revisiting factual findings made by labor tribunals.
3. Employment Rights Under Rehabilitation Schemes: The judgment also addressed the rights of individuals appointed under special schemes for rehabilitation of families affected by land acquisition.
Observations by the Court
1. Judicial Restraint: Emphasizing deference to specialized tribunals, the court remarked, “Labour Courts are equipped to evaluate evidence comprehensively. Their factual conclusions should not be disturbed unless substantial legal or procedural errors are demonstrated.”
2. Purpose of Rehabilitation Schemes: The court underscored the intent behind the rehabilitation schemes, stating, “Such policies aim to ensure stability and opportunities for families affected by large-scale projects. Termination decisions must align with this objective.”
Supreme Court’s Decision
The Supreme Court reversed the Karnataka High Court’s judgment, reinstating the Labour Court’s award. The bench noted that the High Court had erred in disturbing the tribunal’s factual findings, which were supported by evidence, including marital records and the terms of the rehabilitation scheme.
Justice Hrishikesh Roy observed, “The relevant materials reflecting the appellant’s marriage with Smt. Ganga were ignored by the Writ Court. Such factual findings of the Labour Court should not normally be disturbed without compelling reasons.”
While restoring Naik’s employment, the court denied back wages for the period between the High Court’s judgment (December 16, 2020) and reinstatement. However, it ensured that this gap period would count towards other service benefits.
Case Details
– Case Number: Civil Appeal Nos. 6591-6592 of 2024
– Bench: Justice Hrishikesh Roy and Justice S.V.N. Bhatti
– Appellant: Ganapati Bhikarao Naik, represented by Senior Advocate K. Parameshwar.
– Respondent: Nuclear Power Corporation of India Limited (NPCIL), represented by Advocate Shrinkhla Tiwari.
