Non-interference with Labour Court awards involving small monetary stakes despite merits of legal challenge.

The respondent-employee was terminated by the petitioners citing irregular attendance and medical unfitness

The respondent challenged this termination in the Labour Court, which ordered reinstatement with 10% back wages. This was subsequently modified by the High Court in SCA No. 8662 of 2013, which directed reinstatement without back wages. Following reinstatement on 28.07.2014, the employee filed Recovery Application No. 98 of 2015

On 11.05.2023, the Labour Court, Bhavnagar, ordered the petitioners to pay the respondent ₹44,713.50

The petitioners moved the High Court to quash this recovery order

Whether the order passed by the Labour Court in Recovery Application No. 98 of 2015, awarding a sum of ₹44,713.50 to the respondent-workman, warrants interference under Article 226/227 of the Constitution

The court exercised its discretionary jurisdiction under Article 226/227, applying the principle of de minimis non curat lex (the law does not concern itself with trifles) and the doctrine of judicial restraint in matters involving negligible financial stakes.

The court emphasized that when the "smallness of the amount" is a factor, the court may decline to adjudicate on the merits of the legal nuances to prevent the wastage of judicial resources

The Court evaluated the petitioners’ contention that the Labour Court’s award was contrary to law

However, rather than delving into the legality of the lower court’s reasoning or the procedural history of the dispute, the Court focused on the quantum of the award, which totaled only ₹44,713.50

The Court reasoned that due to the "smallness of amount," it was not inclined to interfere with the impugned judgment

To preserve the legal rights of the petitioner for future disputes, the Court expressly stated it was not deciding on the merits and was keeping all grounds raised by the petitioner open

It held that due to the insignificant amount involved, the award of the Labour Court would stand. The Court clarified that this judgment shall not be considered a precedent.

The petitioner was directed to deposit the awarded compensation of ₹44,713.50 to the respondent-employee within six weeks