Chhattisgarh High Court

Labour Court Cannot Redetermine Entitlement Where Reference Specifically Mandates Determination of Arrears Payable.

MUKESH KUMAR VERMA vs NAIDUNIA

Chhattisgarh High CourtJUDGMENT: April 24, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The petitioners were employees of Naidunia Media Limited, which merged with Jagran Prakashan Limited on April 1, 2012

Source reference: p. 5

They sought benefits under the Central Government notifications dated 24.10.2008 and 11.11.2011, which recommended pay scales and interim relief (30% of basic pay) for newspaper employees via the Majithia Wage Board

Source reference: p. 5

Following the respondent's failure to extend these benefits, the petitioners approached the Assistant Labour Commissioner. A reference was made to the Labour Court on 13.12.2017 to determine the specific amount payable to the petitioners under the Wage Board recommendations

Source reference: p. 5-6

However, the Labour Court framed a different issue regarding the "entitlement" of the petitioners and subsequently answered the reference in the negative

Source reference: p. 6

The petitioners challenged these awards via writ petitions

Source reference: p. 6
02

Issues

1. Whether the Labour Court erred in law by deciding the petitioners' "entitlement" to benefits instead of determining the "amount payable" as framed in the original reference by the competent government

Source reference: p. 6, para 3

2. Whether the impugned awards passed by the Labour Court are sustainable given the deviation from the referred question of determination

Source reference: p. 7, para 6
03

Law Applied

The Court applied Section 10 of the Industrial Disputes Act, 1947, which governs the reference of disputes to Boards, Courts, or Tribunals and mandates that the adjudicating authority must confine its decision to the points specifically referred by the competent government

Source reference: p. 7, para 6-7

It further operated under Sections 9 and 13(C) of the Working Journalists and other Newspaper Employees (Conditions of Service) and Miscellaneous Provisions Act, 1955, which provide the statutory framework for the constitution of Wage Boards and the fixation of wages for newspaper employees

Source reference: p. 5, para 1
04

Reasoning

The High Court observed that the reference made by the competent government specifically directed the Labour Court to calculate and "decide the amount payable" to the petitioners as per the Majithia Wage Board recommendations

Source reference: p. 7, para 6

However, the Labour Court exceeded its remit by adjudicating upon the "entitlement" of the employees to receive such benefits in the first instance, rather than performing the duty of quantification as per the reference

Source reference: p. 7, para 7

The High Court reasoned that since the Labour Court failed to address the specific question framed under Section 10 of the Industrial Disputes Act, its findings were legally unsustainable

Source reference: p. 7, para 7

The court emphasized that the determination of the amount was the core task referred, which the lower court neglected

Source reference: p. 7, para 7
05

Holding

The High Court held that the Labour Court's awards were not sustainable as it failed to decide the actual question referred to it

The Court set aside the impugned awards and remitted the matters back to the Labour Court with a direction to decide the specific question for determination framed by the competent government

Source reference: p. 7, para 7

The Labour Court was further directed to conclude proceedings within 180 days, providing sufficient opportunity of hearing to all parties

Source reference: p. 7, para 8

The High Court clarified it expressed no opinion on the merits of the petitioners' claims

Source reference: p. 7-8, para 9
Chhattisgarh High Court

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MUKESH KUMAR VERMAvsNAIDUNIA

Chhattisgarh High Court · April 24, 2026

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