RAMNAGAR CANE & SUGAR CO. LTD. VS. JATIN CHAKRAVORTY AND OTHERS
AIR 1960 SUPREME COURT 1012
FACTS
The company operates a factory in Plassev, in the District of Nadia, and was declared a public utility concern via a government notification. It employs a significant number of workers, both permanent and seasonal. The workforce is divided between two unions: the majority belong to the Ramnagar Cane & Sugar Co. Employees' Union (Employees' Union), and a minority to the Ramnagar Sugar Mill Workers' Union (Workers' Union).
On December 9, 1953, the Workers’ Union presented a charter of demands to the company, followed by a similar charter from the Employees’ Union on January 20, 1954. These demands covered issues affecting the entire workforce.
Concurrent with their presentation of demands, the Workers’ Union served a notice of strike to the company on January 20, 1954.
A conciliation meeting was scheduled on February 1, 1954, attended by the Employees' Union and the company. A notice of this meeting had also been served to the Workers’ Union. The next day, the company proposed discussing matters separately with each union. The Workers’ Union objected to this approach and declared that they assumed the conciliation had failed.
Following the breakdown of discussions with the Workers' Union, the conciliation officer reported a failure of conciliation concerning the Workers’ Union on February 3, 1954.
Despite the ongoing conciliation with the Employees' Union, the Workers' Union commenced their strike on February 13, 1954.
A settlement was reached between the company and the Employees' Union on February 25, 1954, and was formally recorded.
The company initiated legal action against the striking workers under the West Bengal Security Act, 1950, charging them with engaging in a subversive activity by conducting an illegal strike during the pendency of conciliation proceedings.
ISSUE
The core legal issue revolves around the interpretation of Sections 18(3)(d), 22(1)(d), and 24(1)(1) of the Industrial Disputes Act, 1947, particularly whether the strike was illegal given that another union was still engaged in conciliation proceedings with the employer.
CONTENTIONS
Petitioner
The petitioner argued that the strike was illegal under Section 22(1)(d) of the Industrial Disputes Act, 1947. This section prohibits employees in a public utility service from going on strike during the pendency of conciliation proceedings and for seven days after their conclusion. The petitioner contended that since conciliation with the Employees’ Union was still ongoing when the Workers’ Union went on strike, the strike violated this provision.
The petitioner emphasized that any settlement reached during the conciliation proceedings with one union should be binding on all employees, regardless of their union affiliation, under Section 18(3)(d) of the Industrial Disputes Act. This approach ensures that settlements have a broad application and help maintain industrial peace.
The petitioner argued that conciliation proceedings with the Employees’ Union were still active and hadn’t concluded at the time the Workers’ Union initiated the strike, thus fulfilling the criteria for an illegal strike under the Act.
Respondent
The respondents contended that the strike was not illegal because the Workers’ Union had already exited the conciliation proceedings before the strike commenced. They argued that since their union was not involved in the ongoing conciliation, they were not bound by its pendency, and therefore the strike did not contravene Section 22(1)(d) of the Act.
The respondents maintained that the Workers’ Union was independent of the Employees’ Union and had separate representation and interests. They argued that the failure of conciliation with their union exempted them from the restrictions imposed by ongoing proceedings involving another union.
The respondents likely argued based on the trial and high court's rulings that upheld the legality of the strike, asserting that the legal interpretation accepted by lower courts should stand.
HELD
The Supreme Court held that the settlement reached through conciliation with one union was legally binding on all employees, including those who belonged to the rival union. This interpretation rested on the broad policy intent of Section 18 of the Act, which aims to extend the binding effect of conciliation settlements to all employees involved in the dispute, regardless of their union affiliation.
The Court criticized the lower courts for their narrow interpretation, which led to the erroneous acquittal of the workers who participated in the strike. By upholding the settlement's binding nature, the Court emphasized that any strike occurring during the pendency of such conciliation proceedings was illegal.
The Supreme Court set aside the acquittal and convicted the respondents (workers) involved in the strike, imposing a symbolic fine on each. The decision clarified that under the Industrial Disputes Act, strikes during ongoing conciliation proceedings are illegal if they concern issues being negotiated, impacting the entire workforce.