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Krushna Narayan Wanjari v. The Jai Bharti Shikshan Sanstha, Hinganghat

Civil Appeal · Neutral citation not assigned (Civil Appeal Nos. 5965-5966 of 2016)Decided 8 Jul 2016
Civil Appeal Nos. 5965-5966 of 2016
Justice Kurian Joseph · Justice Rohinton Fali Nariman

Background

The Industrial Tribunal in Maharashtra had allowed the appellant's complaint and directed the respondent educational institution to pay him salary for two disputed periods (March 1996-September 1997 and December 2001-October 2002). The institution challenged this before the Bombay High Court, which took the view that muster rolls did not show the appellant was actually present and working, and refused to even consider additional documents the appellant tried to produce in review. The appellant then approached the Supreme Court.

Decision Breakdown

The Court held that the High Court, exercising its limited writ jurisdiction under Articles 226/227, is not a first-appellate court entitled to re-appreciate evidence: it can interfere with an Industrial Tribunal's factual award only if the Tribunal's approach was "wholly perverse," i.e., based on no evidence at all. Since the Industrial Tribunal had examined the full record before awarding the salary, and the appellant's additional documents ought to have been considered, the High Court was not justified in refusing to look into them or in overturning the award. The Supreme Court therefore allowed the appeal, set aside the High Court's orders, and restored the Industrial Court's original order. It further directed that since the institution was a 100% grant-in-aid body, the State itself was liable to pay the awarded salary within three months of production of the judgment, failing which 12% interest would apply and the responsible officers would be personally liable.

Lesson Learnt

When a specialised tribunal (like an Industrial Court) has already examined the evidence and made a finding, a High Court reviewing that decision under its writ powers cannot simply re-weigh the evidence itself: it can only step in if the tribunal's decision had no evidentiary basis at all; ordinary disagreement with the tribunal's assessment is not enough to overturn it.

Official source (sci.gov.in)View Judgment (PDF)

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