DAMODARAM SANJIVAYYA NATIONAL LAW UNIVERSITY

VISAKHAPATNAM, A.P., INDIA

SUBJECT:

Labour Law

NAME OF THE FACULTY:

Mr. R. Bharat Kumar

Topic-
Trade Unions and Their Leadership

Ashirbad Sahoo

Roll No. 2019082

SEM 5

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THE ACKNOWLEDGEMENT

I  would like to express my special thanks of gratitude to my teacher who gave me the golden
opportunity to do this wonderful project on the topic which also helped me in doing a lot of
research and I came to know about so many new things.

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 Index

i. Introduction ........................................................................ 3

ii. Case Analysis .................................................................................... 4

iii. Conclusion .................................................................................24

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 I. INTRODUCTION

Before the emergence of industrialization on a massive scale, there were personal contracts between
the workers and employers. Therefore, no requirement for the evolution of any machinery governing
the relationship between workers and employers arose until then. But after the establishment of
modern factory system this relationship lost its significance due to large scale industrialization which
enticed employers to reduce the cost of production in order to withstand the cut-throat competition in
the market and maximize their profit by using technologically more sophisticated means of production
which in turn resulted in the rise of a new class of workers who were completely dependant on the
wages for their survival which changed the existing employer and employee relationship in which the
employees were exploited by their employers. The conflict of interest between workers and employers
and the distress of workers resulted in the growth of various trade unions.

A trade union is an organized group of workers who strive to help the workers in the issues relating to
the fairness of pay, good working environment, hours of work and other benefits that they should be
entitled to instead of their labour. They act as a link between the management and workers. In spite of
being newly originated institutions, they have turned into a powerful force because of their direct
influence on the social and economic lives of the workers. To control and manage the working of
these trade unions different legislations regulating the same required. In India Trade Unions Act of
1926 is a principal Act for controlling and managing the working of trade unions. The present article
aims at explaining and bringing forth various aspects of the Trade Unions and their leaderships.

II. CASE ANALYSIS

1. Smt. Tarala Hazra and Another v District Magistrate, Andaman and Others

Citation: 1982 Indlaw CAL 12

Facts:

Detenu a popular Trade Union Leader. Alleged that the Union Leader instigated strike by
sweepers. The strike led to grave problem of hygiene and sanitation. So, notification
published only a few days before order of detention was passed.

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Issue:

Whether alleged activities of the Union Leader were prejudicial to maintenance of supplies
and services essential to community?

Reasoning:

Distinction between violation of law and order and violation of public order. Incidents
mentioned in grounds Nos. 1 to 10 and 12, 13 and 14 cannot be said to have affected public
order and cannot be grounds to detain the Union Leader. Strike said to have been organized
by the Union Leader was never declared illegal.

Simply by organizing a strike it cannot be said that he has acted in any manner prejudicial to
maintenance of supplies and services essential to community - Cannot be said that the Union
Leader has caused unhygienic and insanitary, condition of town. So, the grounds of detention
must be pertinent and not irrelevant, proximate and not stale, precise and not vague.

The HC under art.226 and SC under art. 32 or art.136 do not sit on appeal on orders of
preventive detention. Until it is found that either alleged act affects public order or affects
maintenance of supplies and services essential to community, order of detention cannot be
upheld

Judgment:

Held that order of detention cannot be upheld. Appeal was allowed.

2. S. Maran v. The Chairman and Managing Director & Another

Citation: Writ Petition No. 5670 Of 1999

Facts:

The petitioner who was working as an Assistant under the second respondent Senior Regional
Manager, Tamil Nadu Civil Supplies Corporation, has filed the present writ petition
challenging the order dated 27.10.1997 removing him from service and confirmed by the
order of the first respondent dated 07.01.1999.The petitioner was the General Secretary of the
Trade Union to which he belonged, which necessitated him to leave the station often for
union work. He started taking several leave without informing the officers and merely
intimating about his absence.

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The petitioner from 09.10.1995 to 15.12.1995 took medical leave and earned leave, from
16.12.1995 to 10.03.1996, he was kept under compulsory wait seeking for posting in some
other station. Again from 11.03.1996 to 31.08.1996, he took earned leave. From 01.09.1996
to 14.10.1997, he sought for employment and kept under compulsory wait. The department
taking note of the frequent absence of the petitioner, especially for the period from October
1995 to October 1997 he has taken 736 days leave without permission in a period of two
years.

The petitioner contended by saying he has been victimized, being an office bearer of a trade
Union, having affiliation to a particular political party.

Issues:

Whether there is a mala fine intention behind the transfer of Union Trade Leaders?

Reasoning:

A trade Union leader has no right to act differently than that of other workman. When there
are service rules, with reference to leave have been specifically provided for, he cannot stand
on a higher pedestal than the other workman with a defence that he was forced to take leave
because of union work. This kind of defence taken by the petitioner will have no sympathy
from any forum including form this Court. When a charge was framed specifically and the
petitioner does not have any specific defence and he has been imposed with the punishment
of removal and the appellate authority also having rejected the same, it is not open to this
Court to interfere with the said punishment in a writ petition under Article 226 of the
Constitution of India.

The Supreme Court in a recent Judgment in the case of L & T Komatsu Ltd., vs. N.
Udayakumar,1 held that unauthorized absence must be viewed seriously and even labour
Court having power cannot invoke the power to interfere with the punishment.

Judgment:

The writ petition was dismissed.

3. B. S. V. Hanumantha Rao and Another v Dy. Registrar of Trade Unions

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2008 (1) SCC 224.

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Citation: 1987 Indlaw AP 195

Facts:

Petitioners were employees of trade Union Allwyn Limited and filed petition for declaration
that amendments approved by Dy. Registrar were illegal and invalid. They filed an instant
Petition

Issues:

Whether alterations in Rules could be considered to be inconsistent with any of provisions

of the Trade Union Act, 1926 (The Act)?

Whether altered rule was violated any provision of s.6 of the Act?

Reasoning:

It appeared that amendments made by general body consisting President virtually as election
authority was clearly contrary to letter and spirit of the Act. Elections were being conducted
by Labour Department. President who was party vitally interested in conduct of elections
could not be person that could be entrusted with authority to prepare voters' list, to appoint
Returning Officers and to conduct elections. It was case of person being given authority to
perpetuate himself in office, such procedure was not less objectionable than constituting
person Judge in his own cause. It was contrary to provisions of s.6(h) of the Act, which
contemplated Constitution of executive of trade union to be in accordance with provisions of
the Act contemplated appointment and removal of office bearers of trade union. Rules of
Trade Union provided for vesting of authority in President to conduct elections to be
inconsistent with provisions of the Act. Amended rule which denied authority to general body
to remove President before his term of office expired at end of two years was obnoxious to
provisions of the Act and more particularly to s.6 of the Act. Thus, amendments and
alterations of Rules was illegal. Petition allowed.

Answering the second contention the Court said that the general body which was in fixing
term of elected President as two years was not in any way violating any provisions of the Act.
However, general body in so far as it empowered President to nominate office bearers of
executive committee, was acting contrary both to ss.22 and 6(b) of the Act. U/s.22 of the Act,
not less than one half of total number of office bearer should be persons actually engaged or
employed in industry with which Trade Union was connected. Persons actually engaged or

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employed in industries could normally be like petitioners. Altered rule provided that
President could appoint any of members of executive Committee, from any source. Thus, that
altered rule violated provision of s.6 of the Act

Judgment:

Petition was allowed.

4. K. Rengarajan and others v Indian Overseas Bank, Chennai

Citation: 2016 Indlaw MAD 4616

Facts:

Respondent took steps to absorb temporary messengers and sweepers working with
Respondent subject to fulfillment of recruitment norms. Complaints received alleging several
malpractices in absorption and certain persons terminated for forging certificates. Terminated
employees filed complaints complaining that documents produced for absorptions of service
have been forged / fabricated at instance of Appellants. Appellants suspended and department
enquiry and FIR registered. Enquiry was conducted and Respondent accepted findings.
Before taking decision to impose punishment of dismissal, Respondent issued notices
requiring personal hearing on proposed punishment. Petition challenged notices that were
denied.

Issue:

Whether, order passed by Single Judge is justified?

Reasoning:

 It has to be noted that many trade union leaders and office bearers are really working and
fighting for the cause of the workers. The present cases are exceptions
wherein trade union leaders themselves are allegedly involved in misconduct and commission
of offences. This Court cannot lose sight of the fact that a few trade union leaders and office
bearers are indulging in misconduct and also commission of offences making use of their
position as office bearers. The union leaders / office bearers should be above board, when
they are supposed to fight for the cause of the workers. When they themselves are alleged to
be involved in commission of offence, they cannot discharge their duties / obligation
as union leader. Therefore, the workers / staff should be careful enough to elect their office

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bearers or Union leaders with integrity, honesty and sincerity and commitment to cause of
workers and the interest of the institution in which they are employed. Otherwise, this kind of
cases, cannot be avoided, which may not be in the interest of the workers as well as the
institution / Organisation/Industry.

Held, departmental proceedings have been initiated by Bank whereas criminal proceedings
were initiated based on complaint given by third parties, namely, erstwhile employees of
bank. Moreover, allegations in charge sheets and FIR are different and, therefore, there are no
complicated questions of fact and law. Single Judge rightly rejected prayer for keeping
departmental proceedings in abeyance till conclusion of criminal trial. Single Judge made
reference about cl. 4 of Memorandum of Settlement. As per cl. 4, waiting period for
management is one year. Said clause is applicable only when criminal proceedings as well as
departmental proceedings are initiated by Respondent whereas in this case, criminal cases
have been initiated by third parties. Even assuming that criminal cases have been initiated by
department, one year period was already over as observed by Single Judge and no question of
staying of departmental proceedings, pending criminal trial. Single Judge rightly rejected
Appellants' contention. 

Judgment:

Dismissed the petition.

5. Bokaro Steel Workers Union & Anr. v State Of Bihar & Ors.
Citation: 1995 Indlaw PAT 15

Facts:

 Communication was addressed by Labour Commissioner to General Secretary directing that

election to be held under supervisions of Deputy Labour Commissioner failing which action
would be taken in terms of provisions of the Act and code of discipline framed by
department. In petition, HC declined to interfere in matter - Respondent no.3 filed suit before
Munsif who had restrained members of petitioner's faction from functioning as office-bearers
of union - In appeal, District judge affirmed Trial Court's order

Issue:

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Whether there is any provision in the Act justify action of Registrar in issuing directions.

Reasoning:

Held, in a dispute between two rival factions claiming to be office bearers of a trade union, it
is open to Registrar to hold enquiry for the purpose of maintaining and updating registers
required to be maintained u/s.8 of the Act. His decision shall neither confer any right on any
person or group of persons nor divest any person or group of persons of any lawful rights.
Registrar of Trade Unions has no authority or power to direct holding of election of office-
bearers of a union under his own supervision or under the supervision of his nominee. In
absence of any provisions in the Act, any dispute of his kind can only be resolved by means
of a suit filed before a civil Court. However, adjudication in a suit at least is that State is
normally a slow and time consuming process and does not constitute a wholly satisfactory
remedy for resolving the dispute. Thus, impugned directions as contained in letter were
wholly without any authority or jurisdiction and are unsustainable in eye of law. Hence,
impugned directions are accordingly quashed.

Hence, Registrar has no authority or power to issue any direction asking/advising Labour
Department of Govt. or employer to recognize and treat any particular person or group of
persons as duly elected office-bearers of union in dealing with that union.

Judgment:

Application allowed.

6. Chandrakant Bhalekar and Others v Indian Express Newspapers (Bombay)

Private Limited
Citation: 2002 Indlaw MUM 582

Facts:

It appears that the industrial dispute between the petitioners and the respondent company was
not of an individual nature, but it appears from the record that it has a long drawn and
chequered history arising out of the struggle and tussle between the two unions representing
two factions amongst the workmen employed by the respondent company. It appears that
some workmen joined the militant trade union leader Dr. Datta Samant who was having his
hay days during that period and was popular leader to be sought after. It appears that the
workmen wanted in the company his leadership while the other workmen were opposed to

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switch over of the loyalty to the union functioning at that time with the recognition granted
by the respondent-company under the code of conduct. According to the rival union led by
Dr. Samant, the recognised union was not effective as it was favoured by the
management. This is the genesis of the entire trade union dispute or agitations which finally
resulted in 20 charge sheets and finally six dismissal orders, with which we are presently
concerned.

Charge sheet was issued by respondent against petitioners. After completion of enquiry,
petitioners were dismissed. Petitioners approached before Labour Court who rejected their
reference for adjudication of industrial dispute of propriety and legality of dismissal orders
and for relief of reinstatement with full backwages and continuity of service and refused to
grant any relief. Hence, instant Petition for violation of principle of natural justice. So, the
petitioners have, therefore, approached this court u/art. 226 of the Constitution of India to
question the legality and propriety of the said Award of the labour court.

Issues:

Whether there is a violation of natural justice by the labour court?

Reasoning:

Held, enquiry officer has complied with principles of natural justice and there is hardly any
infraction or violation of principles of natural justice. Charge sheeted workmen were
represented by common representatives who were from Journalist category, well educated
and well behaved. It appears that at fag end of enquiry, charge sheeted workmen abandoned
enquiry and did not participate and, therefore, enquiry officer had no other alternative but to
precede ex-parte. Thus, no illegality or infirmity is found in findings recorded by labour
Court. After representatives of petitioners and charge sheeted workmen extended hand of
compromise, management could have put certain terms of apology etc., to put end to entire
affair. It appears that management kept calculated silence. Therefore, management ought to
have come forward by two steps as union-representatives also offered olive breach of peace.
Hence, there is need to quash and set aside award of labour court to extent of denial of
reinstatement to petitioners, as order of dismissal of petitioners was discriminatory and was
not proper and was not justified. It smacks of legal victimization and malafide. Petitioners
are, therefore, entitled to be reinstated in employment.

Judgment:

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Petition partly allowed.

7. Mahabir Das v UCO Bank

Citation: 1993 Indlaw CAL 58; 1995 (1) CLR 874; 1995 (1) LLJ 535

Facts:

Appellant joined service under Bank as clerk and on promotions selected in post of Officer
Grade D and claimed to be president of league. Respondent by order transferred petitioner
from 'A' to 'B'. Petitioner filed application and challenged that order of transfer would
seriously affect interest of Scheduled Castes employees of Bank. Trial Court found that
appellant could not make out case of any discrimination or that order was mala fide or suffers
from any illegality necessitating any interference by Court and application was dismissed.

Issue:

Whether there is a mala fine intention behind the transfer of Union Trade Leaders?

Reasoning:

When under the statutory rules an officer is transferred in that event merely on the ground
that an employee happens to be a union leader could not be transferred would be contrary to
the interest of an organisation. Union leader cannot claim any preferential treatment and/or
any immunity from transfer when transfer is a condition of service and in this regard a
discrimination could not be made between an employee who is not a union leader and an
employee who is a union leader. Under our Constitution an employee has trade union right
subject to conditions and restrictions. The trade union activities are not to be performed
during the office hours inasmuch as an employee is paid by public exchequer for his official
duty and not for his trade union activities. Trade Union activities are to be performed beyond
office hours. In the matter of laying down the principle and guidelines for transfer the
authorities concerned cannot lay done any rule which is contrary to the statutory rules.

Regulation 47 of UCO Bank (Officers') Service Regulations, 1979 says that every officer was
liable to transfer to any office or branch of Bank or to any place of India. Unless it could be
established that order of transfer was in face of it mala fide and was not in interest of
administration or it was violative of any of rules of transfer or like, validity of order of

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transfer could not be challenged on any other grounds. Appellant has completed about 14
years of service in or around X and thus appellant could not claim any protection against the
transfer from one Zone to another. Plea of unlawful discrimination could not be adjudged
unless petition contains full averments of ground on which equality was claimed and denial
of equality was pleaded as not based on rational relation to object sought to be achieved by
actions which makes classification. 'C' and 'D' who were Secretary and President respectively
of Bank SC/ST Council which represents majority members of reserved community and that
'C' and 'D' could not be treated as similarly situated to that of appellant as they were treated as
exempted category. No discrimination had resulted in transferred appellant by respondent.
Transfer was policy matter of Bank and no reason to interfere with order of transfer of
appellant and to interfere with order passed by Trial Court.

So, it is a well settled principle that unless it established that order of transfer was mala fide
and was not in interest of administration or it was violative of any of rules of transfer validity
of order of transfer could not be challenged on any other grounds.

Judgment:

Appeal dismissed.

8. Chhatisagarh Mukti Morcha v. State of M.P

Citation: Writ Petition No. 152 Of 1995

Facts:

The petitioner is a registered political party, which has approached this Court under Art.
226/227 of the Constitution of India for seeking a writ of mandamus or a writ of certiorari or
any other writ, direction or order, directing IInd Additional Sessions Judge. District Durg, in
whose court the 9 accused persons are being tried for commission of the murder of one
Shankar Guha Neogi, a trade union leader, to hold the trial in open Court and other relief.

Issue:

Whether the trial of a Trade Union Leader can be held in camera?

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Reasoning:

Considering the paucity of the space, and the trial being of a trade union leader, the special
public prosecutor made a prayer for holding the trial in camera, which was not opposed by
the accused persons, therefore, the Trial Court ordered trial to be held in camera so as to
avoid inconvenience to the all concerned as the Court room is not enough to accommodate
large number of public. In the opinion of this Court the order of holding trial in camera is
based on a misconceived notion. The Court room is a temple of justice, where everybody
including parties and the complainant have got a right to access, access is not limited to
parties. In case of number of persons being more, the Trial Judge, certainly can regulate the
access in such manner so that the proper and fair administration is not obstructed. Therefore,
the order of the trial Court holding the trial in camera cannot be sustained and is hereby
quashed.

Judgment:

The petition is disposed of with a direction to the trial Court to proceed with the trial
expeditiously in open Court in accordance with law.

9. Peethala Murthy Yadav @ P.L.V.N. Murthy v. Government of A.P.

Citation: Writ Petition No. 3147 Of 2013 | 15-02-2013

Facts:
Petitioner claims to be the General Secretary of I.N.T.U.C. Young Workers Council.
According to him, he is taking up social activities and highlighted various irregularities. It is
also stated that he is the President of Visakha Municipal Corporation Employees & Workers
Union, Rajiv Time Scale Employees Union of Andhra University and Priyadarshini NMR
Employees Union, Andhra University. He contends that Andhra University is without Vice-
Chancellors from August, 2007 onwards, and the In-charge Vice Chancellor and in particular,
the 5th respondent herein, have been taking major decisions contrary to the provisions of law.
He made specific allegations against the 5th respondent.

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According to him, attempts were made by respondent Nos.5, 6 and 7 to fill the vacancies
without any notification and the notice displayed on 17.01.2013, are contrary to law. He
alleged that the 5th respondent has taken all his retirement benefits, but is delaying the same
to others. In effect, the petitioner contends that the entire functioning of the University from
2007 onwards is illegal, untenable and he attributed mala fides to various officials.

Issue:
Whether there is a genuine activity of Trade Union Leader?

Reasoning:
The petitioner claims to be a Trade Union leader. The field of activity for any Trade Union
leader would be optimum and in certain cases, not only an individual but also an organisation
may not be adequate to deal with a particular class of work force, not to speak of the entire
work force, at that place. However, the nature of allegations made against the acting Vice
Chancellor and other officials, and strangely enough, even the Standing Counsel, is indeed
outrageous. In his additional affidavit, the petitioner stated that he is only a matriculate.
However, he proceeds as though he can command the administration of the entire University,
be it in the context of appointment of Professors and other teaching staff or affiliation or
transfer of other colleges.

Hence, the writ petition is dismissed by directing that:

(a) none of the representations made by the petitioner in relation to any matters pertaining to
the University shall be entertained by any authority;
(b) the District Administration shall ignore any representation made by the petitioner unless it
pertains to himself or to genuine activity of Trade Union;
(c) the petitioner shall pay costs of Rs.15,000/- (Rupees fifteen thousand only) to be
deposited in the Tribal Welfare Hostel for Girls in the scheduled area within the District, as
may be identified by the District Collector, to whom a copy of this order shall be marked,
within four weeks from today.

If the petitioner fails to deposit the amount and submit receipt before the District Collector,
he shall not be entitled to undertake any activity even in the field of Trade Union.

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Judgment
The miscellaneous petition filed in this writ petition shall also stand disposed of.

10. P. Mukundan and Others v Mohan Kandy Pavithran

Citation: 1991 Indlaw KER 49; 1992 (2) LLJ 160

Facts:

Defendant no. 1 issued strike notice. It contained usual threat concede demands, or else face a
strike of indefinite duration. Contractor claimed damages from striking workers. Suit was for
damages sustained by Plaintiff. Court below took view that striking workers were liable to
make good loss sustained by Plaintiff since they had admitted that they had tapped coconut
trees and drawn toddy. Workers have come up in appeal

Issue:

Whether, Court below rightly held that striking workers are liable to make good loss
sustained by Plaintiff?

Reasoning:

Plaintiff employer rightly placed considerable reliance on admission that workers had tapped
trees during strike. Court below also saw solid foundation in his admission to decide case
against workers. Defendants admitted that they had tapped trees and drawn toddy cannot now
contend that toddy sold from various shops is not toddy which they had drawn. Indicated
earlier view on this admission and how, notwithstanding the same, liability could not be
fastened on workers. That does not, however, absolve him from charge of neglect or
negligence in discharge of his duty as a trade union leader. His sincerity need not be
doubted. But his ineffective conduct of defence of case cannot but be commented
upon. Those who worked in trade union field were quite often exposed to risky and difficult
lives in early days; they were attracted by glow of idealism. Many who hailed from upper
classes discarded advantages arising from their birth, position or class, for a dear

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dream of transforming world from its squalid conditions. Even those who did not have
benefit of formal education had equipped themselves with trends and tendencies in human
life so as to be effective as trade union leader. Trade union leaders of caliber of first
defendant would be ineffective in a movement which has necessarily to be informed and
dynamic. Whether useful or periodic courses could be started for them by a State noted for its
high level literacy is an aspect which could engage attention of Govt. Compelled by
facts of case, it is sufficient to say that those who espouse cause of weaker
sections of workers cannot afford to be indifferent to exactions of intelligence and thinking
ability.

Judgment:

Appeal allowed.

11. Management of Chidambaram Shipcare Private Limited v Presiding Officer,

Principal Labour and others

Citation: W.P. Nos. 19001 to 19004 of 2009.

Facts:

Petitioner was Shipping Industry, Petitioner failed to resolve dispute related to

revision of wages and forced Union to take up matter before Conciliation Officer under the
Act but fruitless. Respondent no. 1 rejected approval applications on ground that enquiry was
not conducted fairly.

Issue:

Whether employer conducted fair enquiry and workmen was liable for assistance by office
bearer of Trade Union in domestic enquiry?

Reasoning:

Just because Trade Union leader happened to be practicing advocate Enquiry Officer was not

correct in rejecting his representation in enquiry particularly when Presenting Officer was
legally trained person. However, u/cl. 5(f) of Fifth Schedule of the 1947 Act it was incumbent
on employer to provide assistance of office bearer of Trade Union in domestic enquiry to
which workman was member. Central Govt. had made it as conditions of service by
incorporating same in r. 14(4)(ba) of the rules in Model Standing Orders framed by them. It

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was relevant that s.3 of the 1946 Act r/w s. 5 of the 1946 Act made it mandatory that when
employer submits draft Standing Orders for certification Certifying Officer could forward
copy to Trade Unions for hearing. Further, State Govt. could make provision in Model
Standing Orders as had been made by Central Govt. in Model Standing Orders framed by
them in r.14(4)(ba) of the Rules taking into account scheme of the Act. Thus, there was no
infirmity in findings of respondent no.1 in holding that enquiry was not conducted fairly and
while certifying any standing orders Certifying Officer could ensure that workman was given
assistance by office bearer of Trade Union in domestic enquiry to which workman was
member.

Judgment:

Petitions dismissed.

III. CONCLUSION
Trade Union Act of 1926 is welfare legislation that has been enacted to protect the workers in
the organized and unorganized sector from inhuman treatment and protection of their human
rights. As such the legislation contains the provisions for registration, regulation, benefits,
and protection for trade unions. Thereby, the role of the Trade Union Leaders should be
benefitting the workers. 

Trade Union Leaders are important for the democratic development of any country as it puts
up the needs and demands of the workers by collective bargaining. Collective bargaining is
an important aspect of the employer-employee relationship. However, collective bargaining is
not provided to all the trade unions but is only provided to those trade unions which are
recognized. Therefore, the demand for mandatory recognition of trade union which has not
been provided under the Trade Union Act 1926 has been raised time and again by the
workers. Today, the growth of media has resulted in the empowerment of trade unions and

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they have turned into influential pressure groups not only in industrial sectors but also in
agricultural and other allied sectors.

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