Quasi-Judicial Authorities Must Record Reasons and Evaluate Specifically Exhibited Documents to Validate Continuous Service Claims

The petitioners (Budge Budge Company Ltd.) challenged orders dated 05.12.2024 and 07.05.2026 passed by the Controlling Authority and the Appellate Authority under the Payment of Gratuity Act.

The Controlling Authority had granted the private respondent (workman) gratuity for 36 years of continuous service

The Appellate Authority subsequently reduced this to 33 years, dismissing the period from 1976 to 1982 where the workman served in a "budli" capacity, citing a lack of evidence regarding the completion of 240 days of work per year during that tenure

the petitioners contended that the authorities failed to consider specific documentary evidence (Exhibits P-5, P-6, and P-7) which detailed the actual working days and suggested the workman was entitled to only 19 years of gratuity

1. Whether the Controlling Authority and Appellate Authority erred in law by failing to consider and discuss the relevancy of documents marked as exhibits when determining the period of continuous service for gratuity.

2. Whether the onus of proving continuous service during a "budli" tenure lies with the employee or the employer.

The Court emphasized the quasi-judicial powers of the Controlling and Appellate Authorities under the Payment of Gratuity Act, noting their power to compel the production of documents as per the Code of Civil Procedure

It applied the principle that an authority must pass a "reasoned order" by evaluating all evidence on record

Additionally, the court referenced the Supreme Court precedent in Range Forest Officer Vs. S. T. Hadimani, which establishes that the onus of submitting proof of continuous service (completing 240 days in a year) rests upon the employee

The High Court found that while the Controlling Authority had marked several documents (Exhibits P-1 to P-13) provided by the employer, it completely failed to discuss their relevancy or integrate them into its findings

Specifically, Exhibit P-7 (the Gratuity Calculation Sheet) indicated that the workman had only completed 19 years of qualifying service

The Court noted that the Controlling Authority overlooked these records despite them being "in accordance with law"

The Court observed that while the Appellate Authority correctly identified that the employee bore the burden of proof for the "budli" period, it failed to reconcile the employers' provided attendance data with its final determination of 33 years

The High Court set aside the orders dated 05.12.2024 and 07.05.2026. The matter was remanded back to the Controlling Authority with directions to pass a fresh reasoned order within 30 working days, specifically taking into consideration Exhibits P-5, P-6, and P-7 to determine the accurate number of years for which the workman is entitled to gratuity.