Dismissal of challenge to nominal compensation award on grounds of smallness of amount.

The respondent-workman was employed by the petitioner (Range Forest Officer) as a Watchman for approximately four years; his services were orally terminated on 01.06.2015 without compliance with the mandatory provisions of Section 25(F) of the Industrial Disputes Act, 1947 ("I.D. Act")

Aggrieved, the workman raised an industrial dispute; the reference was partly allowed by the Labour Court by award dated 26.08.2022 in REF (LCV) No. 91 of 2016, granting compensation of Rs. 70,000/- in lieu of reinstatement, together with costs of Rs. 5,000/-

Aggrieved by the award, the petitioner-employer approached this Court seeking to quash it

The petitioner contended the workman had not completed 240 days of service in the twelve calendar months preceding termination, rendering Section 25(F) inapplicable

1. Whether the Labour Court's award granting compensation of Rs. 70,000/- in lieu of reinstatement was vitiated on the ground that the workman had not completed 240 days of service in the twelve calendar months preceding the date of termination, so that Section 25(F) of the I.D. Act was not attracted.

2. Whether the Labour Court had misinterpreted Section 25(B) of the I.D. Act (defining "continuous service"), rendering the award contrary to law and liable to be quashed in the High Court's writ jurisdiction.

Section 25(F) of the Industrial Disputes Act, 1947 prescribes the conditions precedent to a valid retrenchment (notice or wages in lieu thereof and payment of retrenchment compensation), compliance with which was absent in the oral termination as pleaded

Section 25(B) of the I.D. Act defines "continuous service," requiring, inter alia, 240 days of service in the relevant twelve-month period for a workman to claim statutory protection

Declining merits-based interference in writ jurisdiction where the amount in dispute was small (Rs. 70,000/-), while expressly keeping the petitioner's legal grounds open

The Court acknowledged the petitioner's contentions that the workman lacked the qualifying 240 days of continuous service and that the Labour Court had misread Section 25(B)

However, instead of testing those contentions against Sections 25(B) and 25(F) on merits, the Court anchored its decision in the quantum involved: observing that "the amount involved in the present petition is only Rs.70,000/-," the Court held that, "considering the smallness of amount," the petition was "required to be dismissed," "without going into the merits of the matter by keeping all the grounds raised by the petitioner open"

The proportionality of judicial intervention to the modest monetary stake thus displaced a merits review of the Labour Court's construction of the I.D. Act

Rule was discharged and the interim relief granted earlier was vacated forthwith

The petitioner-employer was directed to deposit the compensation awarded by the Labour Court to the respondent-employee within a period of six weeks from the date of the judgment, if not already deposited

This oral judgment passed in light of the facts and circumstances of the present case and shall not be considered as precedent.