Court emphasizes leniency in limitation for workmen-related cases, acknowledging pandemic impacts and Supreme Court directives.
In a significant ruling, the Madhya Pradesh High Court has upheld the Industrial Court's decision to condone the delay in filing claims by workmen affected by the closure of Medicaps Limited's plant. The judgment was delivered in the case of Medicaps Limited Through Factory Manager v. Smt. Sanju and Others, emphasizing the need for a lenient approach in cases involving workmen's rights, especially in light of the COVID-19 pandemic and beneficial legislations.
The case revolves around the closure of Medicaps Limited's industrial plant on November 22, 2019, following which employees filed applications challenging the closure under Sections 31(3), 61, and 62 of the Madhya Pradesh Industrial Relations Act, 1960. The Labour Court initially rejected these applications, affirming the legality of the plant's closure. Subsequent appeals by the employees were also dismissed by the Industrial Court.
However, the onset of the COVID-19 pandemic and the resultant nationwide lockdown complicated matters for the affected employees. A fresh application was filed by the workmen, seeking condonation of delay due to the pandemic's impact. The Labour Court dismissed this application based on the limitation prescribed under Section 62 of the MPIR Act, which mandates a one-year period for such claims.
The Industrial Court, however, took a different view, aligning with the directions issued by the Hon'ble Supreme Court to extend the limitation period during the COVID-19 pandemic up to February 2022. The Court held that the delay in filing deserved to be condoned, citing the workmen's lack of literacy and the extraordinary circumstances posed by the pandemic. Consequently, the case was remanded back to the Labour Court for fresh adjudication.
Medicaps Limited challenged the Industrial Court's decision, arguing that the delay was not adequately explained and that the closure had already been deemed legal in prior judgments. The company contended that the workmen had failed to justify the delay beyond the COVID-19 period.
Despite these arguments, the High Court found merit in the Industrial Court's decision, emphasizing the need for a lenient approach towards limitation in workmen-related cases. The Court referenced the Supreme Court's directive in Inder Singh v. State of Madhya Pradesh, which advocated for leniency in limitation, particularly in cases involving beneficial legislations for workmen.
The judgment underscores the judiciary's recognition of the pandemic's impact on legal proceedings and the necessity to protect workmen's rights through beneficial legislations. The High Court's dismissal of Medicaps Limited's petition paves the way for the Labour Court to adjudicate the matter afresh, allowing the petitioner to raise all contentions during this process.
As the legal landscape continues to adapt in response to unprecedented challenges like the COVID-19 pandemic, this ruling serves as a pivotal reminder of the importance of flexibility and empathy in judicial processes, especially concerning vulnerable groups like workmen.
Bottom Line:
Labour Law - Delay in filing claim by workmen must be considered leniently in light of the COVID-19 pandemic and beneficial legislations protecting workmen's rights.
Statutory provision(s): Industrial Disputes Act, 1947, Madhya Pradesh Industrial Relations Act, 1960 Sections 31(3), 61, 62
