Labour Court findings on the lack of employer-employee relationship based on documentary evidence are not subject to writ interference.

The petitioners, claiming to be "Pattern Masters" (skilled workmen) since 2016, challenged their alleged illegal termination by the respondent as a violation of Section 25N of the Industrial Disputes Act, 1947

The respondent contended that the petitioners were independent "consultants" and not employees

The Labour Court dismissed the claims, finding no employer-employee relationship existed between the parties

Evidence showed the petitioners signed consultancy agreements, received payments against invoices, and filed tax returns under the head of ‘Income from Business and Profession’ rather than 'Salary'

The petitioners approached the High Court seeking a writ of certiorari against the Labour Court’s awards

1. Whether an employer-employee relationship existed between the petitioners and the respondent to qualify the petitioners as "workmen" under the Industrial Disputes Act

2. Whether the High Court, in the exercise of its supervisory jurisdiction under Article 226/227, can interfere with the factual findings of the Labour Court regarding the nature of employment

The court primarily applied the definition of "workman" and the requirements for termination under the Industrial Disputes Act, 1947

It relied on the "control and supervision" test and the "intent of documentation" regarding consultancy agreements

The standards for writ jurisdiction established in Indian Overseas Bank v. I.O.B. Staff Canteen Workers' Union, which restricts High Courts from reappreciating evidence unless findings are perverse

Syed Yakoob v. K.S. Radhakrishnan, which limits the writ of certiorari to errors of law apparent on the face of the record rather than errors of fact

The Court observed that the petitioners failed to provide documentary evidence to support an employment relationship, relying solely on oral affidavits

The respondent produced consultancy agreements (admitted by the petitioners during cross-examination), TDS certificates in Form 16A (used for non-salary payments), and ITRs where the petitioners themselves declared income from "Business and Profession"

The Court found that Clause 12 of the agreement, though requiring specific hours, did not override the overarching contractual framework identifying the petitioners as independent professionals

Applying the principle of judicial restraint, the Court reasoned that the Labour Court’s findings were based on a plausible appreciation of evidence and were not perverse or unsupported

The Court found no manifest error of law or perversity in the Labour Court’s awards; consequently, the writ petitions were dismissed, affirming the Labour Court's decision that the petitioners were consultants and not employees