An appellate authority must give independent reasons, not merely reproduce the controlling authority’s findings.

The petitioner, proprietor of Shantinatha Press, challenged orders awarding gratuity to respondent No. 3, a former employee.

The petitioner contended that the establishment employed fewer than ten employees and therefore was not covered by the Payment of Gratuity Act, 1972.

The Controlling Authority accepted evidence that the press had more than ten employees and allowed the employee’s claim.

The petitioner appealed under Section 7(7) of the Act and sought to produce additional documents; the Appellate Authority dismissed the appeal.

Whether the Appellate Authority’s dismissal of the appeal, without recording an independent decision or reasons, complied with Rule 18(6) of the Payment of Gratuity (Central) Rules, 1972.

Whether the Appellate Authority’s failure to give reasons warranted quashing its order and remitting the appeal for fresh consideration.

Section 7(7) of the Payment of Gratuity Act, 1972 provides for an appeal to the Appellate Authority.

Rule 18(6) of the Payment of Gratuity (Central) Rules, 1972 requires the Appellate Authority, after providing the parties a reasonable opportunity of being heard, to record its decision and make an appropriate order.

An appellate order that merely reproduces the lower authority’s findings without giving the appellate authority’s own decision and reasons fails to meet that requirement and violates the principles of natural justice.

The Appellate Authority had extracted the parties’ pleadings and submissions, but did not independently determine the issues raised in the appeal or give reasons for dismissing it; it merely reproduced the Controlling Authority’s findings.

The High Court held that this did not satisfy Rule 18(6), which required the Appellate Authority to record its own decision after hearing the parties.

The resulting failure to provide a reasoned appellate determination also contravened natural justice.

The Court therefore resolved the matter on this procedural ground without deciding the underlying dispute about the establishment’s employee strength.

The Appellate Authority’s order dated 16 July 2021 was quashed, and the appeal was remitted for fresh consideration after giving both parties a reasonable opportunity of hearing.

The Appellate Authority was directed to dispose of the appeal as expeditiously as possible, preferably within six months of receiving the High Court’s order.