Labour Court must first frame preliminary issue on domestic enquiry validity and independently adjudge punishment proportionality.

Following an incident on March 20, 2007, involving an unlawful assembly of approximately 1,500 workers who allegedly vandalized property and injured the Manager at Borjan Tea Estate, eleven workmen were charge-sheeted for gross misconduct.

Domestic enquiries were conducted, and based on reports finding them guilty, the management dismissed the workmen on September 8, 2007.

An industrial dispute was referred to the Labour Court, Dibrugarh, in 2008.

The management relied on the domestic enquiry reports but reserved the right to adduce further evidence if the enquiries were found defective.

The Labour Court upheld the dismissals via an Award dated February 29, 2016, without first framing a preliminary issue on the validity of the domestic enquiries.

The workmen challenged this Award via a writ petition.

1. Whether the Labour Court committed a jurisdictional error by failing to first frame and decide a preliminary issue regarding the legality and validity of the domestic enquiries.

2. Whether the Labour Court failed to exercise its jurisdiction to decide on the proportionality of the punishment under Section 11-A of the Industrial Disputes Act.

3. Whether the domestic enquiry reports were perverse and in violation of the principles of natural justice.

The Court primarily applied Sections 10 and 11-A of the Industrial Disputes Act, 1947, which empower Labor Courts to adjudicate disputes and interfere with discharge or dismissal orders if the punishment is disproportionate.

The Court strictly followed the procedural mandates established in M.L. Singla v. Punjab National Bank (2018) 18 SCC 21 and Kurukshetra University v. Prithvi Singh (2018) 4 SCC 483, which dictate that when a dismissal is based on a domestic enquiry, the Labour Court must first decide the validity of that enquiry as a preliminary issue before proceeding to the merits or proportionality.

The High Court found that the Labour Court committed a "jurisdictional error" by failing to frame a preliminary issue on the domestic enquiry's validity.

Procedurally, the Labour Court allowed evidence on all issues simultaneously, which contradicted the sequence mandated by M.L. Singla.

Substantively, the High Court noted that the Enquiry Officer admitted he did not inform the workmen of their right to adduce evidence.

The Enquiry Officer's findings were deemed perverse because they relied heavily on a witness (Head Clerk/M.W. 2) who admitted under cross-examination that he could not remember the names of the workmen involved in the 1,500-person mob.

The Labour Court failed to exercise its statutory duty to evaluate the proportionality of the punishment (dismissal) even after upholding the enquiry, rendering the Award legally unsustainable.

The Court remanded the matter to the Labour Court, Dibrugarh, with directions to decide the original Reference on its merits based on the existing evidence on record and to conclude proceedings within three months from June 22, 2026.