Dismissal of challenge against leave encashment order on the ground of smallness of the amount involved.

The respondent-workman was appointed as a labourer on 01.01.1971 in the Road and Building Department and retired upon superannuation on 31.12.2006.

Alleging non-payment of leave encashment for 300 days amounting to Rs. 59,520/-, the respondent filed Recovery Application No. 145 of 2017 under Section 33(C)(2) of the Industrial Disputes Act, 1947.

The petitioners (State) contended that the respondent had received all benefits under Government Resolution (GR) dated 17.10.1988 and was ineligible for leave encashment per a subsequent clarification dated 12.08.1991.

The Labour Court, Dahod, allowed the application on 28.09.2021, directing the State to pay Rs. 33,574/- plus costs.

The State challenged this order via the present Special Civil Application.

1. Whether the impugned order of the Labour Court directing payment of leave encashment was arbitrary and contrary to Government Resolutions.

2. Whether the High Court should interfere with the lower court's order given the specific quantum of the monetary claim involved.

The court's jurisdiction was invoked under Article 226/227 of the Constitution of India regarding a recovery certificate issued under Section 33(C)(2) of the Industrial Disputes Act, 1947, which provides a summary remedy for the recovery of money due to a workman from an employer.

Government Resolution dated 17.10.1988 regarding the benefits admissible to daily-wage workers.

The principle of de minimis non curat lex (the law does not concern itself with trifles), specifically the "smallness of amount" doctrine, to decline judicial review.

The petitioners argued that the Labour Court exceeded its jurisdiction by granting benefits contrary to the restrictive clarifications of the 1988 GR and noted that similar legal challenges regarding these benefits are pending before the Supreme Court.

The High Court declined to adjudicate the substantive legal merits of the eligibility for leave encashment under the 1988 GR.

The Court's reasoning was centered entirely on judicial economy and the "smallness of the amount" involved, which totaled only Rs. 38,575/- (including costs). The Court determined that the expenditure of further judicial time and state resources on such a "meagre amount" was unwarranted, regardless of the potential legal errors alleged by the State.

The Court expressly clarified that because the judgment was delivered based on the low stakes of the litigation, it shall not be considered a legal precedent for future cases involving similar disputes under the 1988 Resolution.

The petitioners were directed to deposit the sum of Rs. 33,574/- plus Rs. 5,001/- in costs with the respondent-workman within six weeks.