State liable for compensation despite missing records where officer admits regular engagement of daily-rated laborers.

Six workmen (respondents) challenged their termination before the Labour Court, asserting they had served as forest watchmen for six continuous years.

Though the State denied continuous service, it failed to produce attendance or wage registers despite a court order, producing only a cash book.

A Range Forest Officer (RFO) testified that the workers were daily-rated and worked 15–18 days per month.

The Labour Court found a violation of Section 25F of the Industrial Disputes Act and ordered reinstatement with partial back wages.

On writ appeal, one Single Judge upheld the relief for two workers, while another Single Judge set aside the relief for the remaining four.

Both the State and the workmen appealed these conflicting decisions.

1. Whether the workmen had completed 240 days of continuous service in a year, rendering their termination without statutory compliance illegal.

2. Whether reinstatement is the appropriate remedy given the passage of time since termination.

The court primarily applied Section 25F of the Industrial Disputes Act, 1947, which mandates procedures for the retrenchment of workmen who have completed one year of continuous service (240 days).

The court invoked the principle of adverse inference regarding the non-production of mandatory employment records (attendance and wage registers) by the employer.

The court relied on the precedent set in LPA No. 908/2023 (decided 18.04.2024), establishing that lump-sum compensation may be awarded in lieu of reinstatement where significant time has elapsed since the termination.

The court found that the State failed to rebut the workmen's claims because it did not produce the attendance registers despite being ordered to do so.

Crucially, the court relied on the RFO’s admission that the workmen were engaged for 15–18 days every month; the court reasoned that this regular monthly engagement, coupled with the State's failure to provide exact records, created a legal presumption that the 240-day threshold was met.

While the court upheld the finding of illegal termination, it analyzed the feasibility of reinstatement 11 years after the 2015 termination. It determined that since the workmen would have likely "moved on in life," reinstatement was improper and substituted it with monetary compensation based on recent Division Bench benchmarks.

The court dismissed the State’s appeals and partially allowed the workmen’s appeals, ordering the State to process these payments within two months.