Industrial Disputes Act; A workman designated as “Manager” remains a "workman"

Supreme Court Upholds Labour Court’s Decision Reinstating Cashier as 'Workman' Designation Not Decisive in Determining 'Workman' Status, Supreme Court Confirms

In a significant judgment delivered on December 17, 2025, the Supreme Court of India upheld the decision of the Labour Court, reinstating Srinibas Goradia, who was terminated from his position as a cashier at M/s Sai International Hotels Private Limited in Rayagada. The apex court emphasized that the designation or nomenclature of an employee does not solely determine their status as a "workman" under the Industrial Disputes Act, 1947.

The Supreme Court bench comprising Justices Prashant Kumar Mishra and N.V. Anjaria granted the appeal filed by Goradia, challenging the decision of the High Court of Orissa, which had set aside the Labour Court's judgment. The primary question addressed was whether Goradia fell within the definition of "workman" under Section 2(s) of the Industrial Disputes Act.

The Labour Court had previously found Goradia to be a "workman" and held that his termination was illegal due to non-compliance with Section 25-F of the Act, which mandates specific procedures for the termination of a workman. The Labour Court directed that Goradia be reinstated with full back wages.

The Supreme Court, while analyzing the evidence and applying the "dominant nature test," concluded that Goradia's duties were non-supervisory and primarily manual, despite his designation as a manager or executive. The court noted that the substantial nature of his work was clerical, which qualified him as a "workman."

Justice Anjaria, writing the judgment, emphasized that the dominant nature of the work performed, rather than the designation, should be the determining factor in classifying an employee as a "workman." The court criticized the High Court's reliance on the designation and unsupported assertions by the employer, reaffirming the Labour Court's findings.

The judgment reinstates the Labour Court's decision and directs M/s Sai International Hotels Private Limited to comply with the reinstatement order within two weeks. This decision serves as a precedent, reinforcing the principle that the nature of work, rather than the title, governs the classification of employees under labor laws.

Bottom Line:

Industrial Disputes Act, 1947 - Determination of whether an employee is a "workman" under Section 2(s) - Dominant nature test is crucial in ascertaining the primary nature of work assigned to an employee.

Statutory provision(s): Industrial Disputes Act, 1947 Section 2(s), Section 25F

Srinibas Goradia v. Arvind Kumar Sahu, (SC) : Law Finder Doc Id # 2823595