A Section 33C(2) court may compute consequential benefits granted by the underlying award.

Kanai Lal Manna obtained an ex parte award directing his reinstatement and payment of full back wages and consequential benefits from dismissal until reinstatement.

He had superannuated on 23 March 2013 while the reference was pending.

He later applied under Section 33C(2) of the Industrial Disputes Act, 1947, to recover money under the award; he died during those proceedings, and his wife continued as his legal heir.

The Labour Court partly allowed the application and directed the employer to pay Rs. 1,85,835 with 10% annual simple interest.

The employer challenged that order, arguing, among other things, that the Labour Court had exceeded the original award.

1. Whether the Labour Court, in proceedings under Section 33C(2), granted relief beyond the original award.

2. Whether the calculation of the workman’s claim period was erroneous in light of his superannuation.

Section 33C(2) of the Industrial Disputes Act, 1947, provides for computation of money or benefits due to a workman under an existing right.

The court treated the original award’s direction for full back wages and “other consequential benefits” from dismissal until reinstatement as the governing entitlement.

The judgment records the employer’s reliance on State Bank of India v. Ram Chandra Dubey, AIR 2000 SC 3734, and other authorities concerning the limits of Section 33C(2), but does not develop or apply those precedents in its reasoning.

The court found that the original award had already granted full back wages and consequential benefits, and concluded that the Labour Court’s order did not exceed that entitlement.

It noted that the claim period was incorrectly recorded in the impugned order as March 2018 to March 2023; the correct period was March 2008 to March 2013.

Since the workman’s date of birth was 23 March 1955 and he superannuated at age 58 on 23 March 2013, the court considered the impugned order lawful and found no basis to interfere.

It also rejected the challenge to interest, reasoning that interest was included among the consequential benefits granted by the original award.

The writ petition was dismissed, and any connected applications were disposed of accordingly.