Court Rules that Labour Courts and Tribunals to Continue Functioning Until New Tribunals Under Industrial Relations Code, 2020 Are Constituted
In a significant ruling, the Karnataka High Court has upheld the validity of an order dated December 19, 2025, which referred a dispute between Glastronix LLP and the Glastronix Karmika Sangha to the Industrial Tribunal in Bengaluru. This decision, delivered by Justice Anant Ramanath Hegde, addresses the legal challenges posed by the transition from the Industrial Disputes Act, 1947 to the Industrial Relations Code, 2020.
The case centered around the applicability of the Industrial Relations Code, 2020, which repealed the Industrial Disputes Act, 1947, effective November 21, 2025. Glastronix LLP challenged the reference order on the grounds that the new Code had already come into effect, rendering the order invalid.
Justice Hegde clarified that although the Industrial Disputes Act was repealed, the amendment to Section 104 of the Industrial Relations Code, enacted on February 16, 2026, ensures that existing Labour Courts and Tribunals continue to operate until the new Tribunals under the Code are established. This amendment, encapsulated in Section 104(1A), explicitly extends the jurisdiction of statutory authorities under the repealed Act until the transition is complete.
The Court also invoked Section 6 of the General Clauses Act, 1897, which safeguards actions taken under a repealed statute, thereby preserving the validity of the reference order issued when the Industrial Disputes Act was still in force.
The judgment emphasized that the term "statutory authorities" in the amended Code includes Labour Courts, allowing them to maintain jurisdiction. Despite the repeal of the 1947 Act, the Court found that the legislative intent was to ensure a seamless transition to the new Code without disrupting ongoing legal proceedings.
This decision is pivotal in affirming the continuity of legal processes amid legislative changes and provides clarity on the functioning of Labour Courts during the transitional phase to the Industrial Relations Code, 2020.
Bottom Line:
Industrial Relations Code, 2020 - Repeal of Industrial Disputes Act, 1947 - Tribunals, Labour Courts, and statutory authorities under the repealed Act to continue functioning until Tribunals under the Code, 2020 are constituted.
Statutory provision(s): Industrial Relations Code, 2020 Sections 51, 103, and 104, General Clauses Act, 1897 Section 6
