Employment LawSC Reinstates Job Under Rehabilitation Scheme, Upholds Labour Court Findings

The Hon’ble Supreme Court of India in the case of Ganapati Bhikarao Naik v. Nuclear Power Corporation of India (2024 INSC 871) decided on 13 November 2024  reinstated the Appellant’s employment under a rehabilitation scheme, underscoring the need for careful consideration of evidence in employment disputes, and the respect for factual findings made by specialized tribunals.

FACTS

Ganapati Bhikarao Naik (hereinafter referred to as “the Appellant”) applied for a job under a rehabilitation scheme for families affected by land acquisition for the Kaiga Atomic Power Project. He claimed eligibility as the son-in-law of the landowner, Bellanna Venkanna Gowda. He stated that he had married Gowda’s daughter, Ganga, in 1990. Official documents, including an attestation form and ration card, identified Ganga as his wife. Based on this, he secured the job as a helper in the Nuclear Power Corporation of India (hereinafter referred to as “Respondent”).

Over time, the Appellant and his wife experienced marital discord. Subsequently, the Appellant’s wife moved back to her father’s home, and the couple eventually got divorced in 2001. Despite this, Ganga’s father initially supported the Appellant’s job. He submitted a letter in 1997 stating that his family had no objection to the Appellant continuing in the job.

In 2000, allegations arose that the Appellant had falsely claimed to be Ganga’s husband to secure the job. An inquiry followed, and his employment was terminated in 2002. He challenged this under the Industrial Disputes Act 1947 (hereinafter referred to as “ID Act”) and the learned Labour Court ruled in his favor. The court found that he was indeed married to Ganga at the time of appointment. It ordered his reinstatement with full back wages and other benefits.

The employer challenged this decision in the Hon’ble High Court. The Hon’ble High court overturned the Learned Labour Court’s order, alleging that the Appellant had secured the job through fraud. Against this ruling, the Appellant filed the present appeal before the Hon’ble Supreme Court.

ISSUE BEFORE THE HON’BLE SUPREME COURT

Whether the Appellant had lawfully secured his job under the rehabilitation scheme as a member of the land-loser’s family, based on his marriage to Ganga, the daughter of the landowner?

CONTENTION OF THE PARTIES

The Appellant argued that he was legally eligible for the job under the rehabilitation scheme. He stated that his marriage to Ganga, the daughter of the land-loser, fulfilled the scheme’s requirement of being a family member of the affected party. Official records, such as his attestation form and ration card, supported this claim. These documents identified Ganga as his wife at the time of his appointment, which was also verified by the employer.

The Appellant contended that his termination was unjust and motivated by personal disputes with Ganga, who had moved back to her father’s home before the divorce. He emphasized that Ganga’s father initially supported his employment, as shown in written communications to the employer. Furthermore, he relied on the Learned Labour Court’s findings, which determined that he was lawfully married and had not engaged in fraud.

The Learned Labour Court’s decision to order his reinstatement, along with back wages and other benefits, was presented as valid and based on evidence. The Appellant also argued that the High Court’s decision to overturn the Learned Labour Court’s findings ignored critical evidence and procedural fairness. He sought relief from the Supreme Court to reinstate him and uphold his employment rights.

The Respondent argued that the Appellant misrepresented facts to obtain the job fraudulently. They argued that the Appellant’s marriage to Ganga, which was central to his eligibility under the scheme, had effectively ended due to estrangement and eventual divorce. This, they claimed, disqualified him from being considered a family member of the land-loser.

The Respondent contended that the Labour Court’s decision was flawed and ignored the evidence showing that Ganapati was not genuinely eligible. They argued that his relationship with Ganga was presented inaccurately during the job application process. They maintained that this amounted to fraud and misrepresentation.

The Respondent supported the High Court’s ruling, which overturned the Labour Court’s decision. They emphasized that the Appellant’s employment violated the conditions of the rehabilitation scheme. The Respondent further claimed that the Appellant’s ineligibility became evident during the inquiry that led to his termination. The Respondent requested the Supreme Court to uphold the High Court’s judgment, asserting that the Appellant had no lawful claim to the job under the scheme. They also argued that reinstating him would undermine the purpose of the rehabilitation program, which was intended solely for legitimate beneficiaries.

DECISION AND FINDINGS

The Hon’ble Supreme Court ruled in favour of the Appellant, and reinstated his employment under the rehabilitation scheme. The Supreme Court found that the Learned Labour Court’s decision, which determined that the Appellant was lawfully married to Ganga and eligible for the job, was supported by sufficient evidence. It was noted that official documents, such as the attestation form and ration card, clearly recorded Ganga as the Appellant’s wife at the time of his appointment.

The Supreme Court observed that the High Court failed to appreciate the procedural and factual conclusions reached by the Learned Labour Court, which had thoroughly examined the relationship between the Appellant and Ganga. The Supreme Court held that the High Court’s decision was based on speculative reasoning and lacked compelling grounds to disturb the Labour Court’s factual findings.

However, the Supreme Court denied the Appellant’s back wages for the period from the High Court’s judgment to his reinstatement. It ruled that the period would count toward his service tenure for calculating other benefits. The Supreme Court directed his reinstatement within four weeks. This judgment emphasized the importance of respecting the factual findings of specialized tribunals like the Labour Court.

AMLEGALS REMARKS

The Supreme Court emphasized that High Courts should avoid overturning the factual findings made by specialized tribunals, such as the Labour Court, unless there are compelling reasons. By reinstating the Appellant, and relying on documented evidence, the Supreme Court reinforced the need for thorough consideration of all facts, including official records and written communications.

The Supreme Court’s decision to deny back wages but allow other service benefits for the gap period reflects a fair compromise, considering both the Appellant’s right to reinstatement and the employer’s concerns about procedural integrity. This case, thus, highlights the balance that must be struck between protecting an individual’s employment rights and ensuring the integrity of the rehabilitation schemes meant for genuine beneficiaries.

Team AMLEGALS