SAIL ordered to pay former Durgapur Steel Plant teachers ₹1.5 lakh for each year of daily-wage service

The petitioners were teachers engaged by the Durgapur Steel Plant (DSP), under the Steel Authority of India Limited (SAIL), on a daily-wage basis during successive academic years from 2009 to 2015, with breaks during vacations.

In 2015, after obtaining an order from the Provident Fund authorities concerning provident-fund contributions and benefits, they were disengaged.

Their appointment terms provided for payment only for days worked and excluded benefits such as medical facilities and leave.

The Central Administrative Tribunal dismissed their applications, finding no right to reinstatement or regularisation; the teachers challenged that decision before the High Court.

Whether, in light of the petitioners’ short period of service and long absence from employment, reinstatement with continuity and back wages was appropriate or practicable.

Whether the Tribunal’s decision should be modified to award monetary compensation for the petitioners’ successive years of service.

The Court relied on Mohan Lal v. Management of M/s. Bharat Electronics Ltd., (1981) 3 SCC 225; Jagbir Singh v. Haryana State Agriculture Marketing Board, (2009) 15 SCC 327; Assistant Engineer, Rajasthan State Agriculture Marketing Board v. Mohan Lal, (2013) 14 SCC 543; Assistant Engineer, Rajasthan Development Corporation v. Gitam Singh, (2013) 5 SCC 136; BSNL v. Man Singh, (2012) 1 SCC 558; BSNL v. Bhurumal, (2014) 7 SCC 177; and Bhavnagar Municipal Corporation v. Salimbhai Umarbhai Mansuri, (2013) 14 SCC 456.

The principle drawn from these decisions was that where an employee has worked for a relatively short period but has remained out of employment for a long time, reinstatement with continuity and back wages may be impracticable or unproductive; reasonable monetary compensation may instead be awarded for the service rendered.

The Court also noted the petitioners’ claims concerning provident-fund coverage under the Employees’ Provident Funds and Miscellaneous Provisions Act, 1952, and clarified that their provident-fund dues would be additional to the compensation awarded.

The petitioners had worked for six years in successive academic years, but had been out of employment for eleven years by the time of the judgment.

The Court considered reinstatement with continuity and back wages impracticable in those circumstances, consistently with the cited Supreme Court decisions.

It nevertheless found that the Tribunal had failed to consider compensation despite the petitioners’ prolonged service on low daily wages and the terms of their engagement, which excluded ordinary employment benefits.

Taking account of their service, the last-drawn daily rate and the passage of time, the Court fixed compensation at Rs. 1.5 lakh per academic year of service.

SAIL/DSP was directed to pay each teacher Rs. 1.5 lakh for every academic year of service, calculated according to the individual’s service record, within 45 days.

If payment was delayed, simple interest at 6% per annum would accrue until payment.

Provident-fund dues and accumulations remained payable separately from the compensation.

The Court declined to restrict the judgment to the petitioners alone and held that similarly placed teachers could cite it.