Administrative Latches and Resiling From Categorical Admissions Preclude Discretionary Relitigation Under Article 226

The Petitioner challenged an order dated 04.12.2023 passed by the Regional Labour Commissioner (Central) (“the Authority”) under the Minimum Wages Act, 1948.

Respondent No. 1, a security guard, alleged he was paid less than the minimum wages prescribed for his category.

Before the Authority, the Petitioner filed a written reply admitting the claimant's entitlement to Central Government wage rates and stated that an "extra budget" would be sought to pay the difference.

The Authority noted that no action was taken on this undertaking and directed the Petitioner to pay Rs. 1,62,951/- (representing the wage difference plus double compensation).

The Petitioner approached the High Court approximately 15 months after the impugned order was passed, attributing the delay to administrative lapses and relocation of offices.

1. Whether the writ petition is liable to be dismissed on the grounds of inordinate delay and laches.

2. Whether the Petitioner can resile from its prior admission/undertaking made before the Authority regarding the applicability of Central Government minimum wage rates.

The court emphasized the doctrine of laches in writ jurisdiction under Article 226 of the Constitution, noting that while no fixed limitation period exists, unreasonable delay is a ground for dismissal.

The court relied on Sudama Devi v. Commissioner [(1983) 2 SCC 1] and Mrinmoy Maity v. Chhanda Koley [(2024) 15 SCC 215], which establish that "delay defeats equity" and the court should not assist the "tardy and the indolent".

The court applied the principles from Postmaster General v. Living Media India Ltd. and Shivamma v. Karnataka Housing Board [2025 SCC OnLine SC 1969], holding that "bureaucratic red tape" or administrative inefficiency does not constitute "sufficient cause" for condoning delay by the State.

The Court found the Petitioner’s explanation for the 15-month delay—comprising administrative approvals, office shifting, and counsel misplacing documents—to be an "excuse" rather than a valid "explanation".

Citing recent Supreme Court precedents, the court held that State instrumentalities must be judged by the same standards as private litigants regarding diligence.

On the merits, the Court observed that the Petitioner had explicitly conceded to the applicability of Central Government wage rates in its reply before the Authority.

Consequently, the Court determined that the Petitioner's attempt to retract this unequivocal stance in the writ proceedings was untenable and a breach of its own prior undertaking.

It held that the petition was barred by laches as the administrative delays cited were insufficient to justify the 15-month lag.

The Court held that the Petitioner was bound by its admission before the lower Authority and could not challenge an order that was based on its own undertaking to pay the wage difference.

All pending applications were disposed of.