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Maharashtra State Road Transport Corporation v. Mahadeo Krishna Naik

Civil Appeal · 2025 INSC 218Decided 14 Feb 2025
C.A. No.-013834-013834 - 2024
Justice Dipankar Datta · Justice Sandeep Mehta

Background

Mahadeo, a bus driver for the Maharashtra State Road Transport Corporation, was dismissed after a 1996 accident in which a lorry collided with his bus, killing two passengers. The Labour Court and a single judge of the Bombay High Court upheld his dismissal, finding the departmental inquiry fair. Years later, Mahadeo discovered that in separate compensation proceedings before the Motor Accidents Claims Tribunal (MACT), the Corporation itself had, on sworn affidavit, blamed the lorry driver entirely for the accident and been absolved of liability: a fact it never disclosed to the Labour Court. On review, the High Court set aside Mahadeo's dismissal and the Labour Court's award, granting him full back wages; the Corporation appealed to the Supreme Court.

Decision Breakdown

The Supreme Court held the Corporation was guilty of "suggestio falsi" (making a false representation) and "suppressio veri" (suppressing the truth) by taking one position before the MACT (blaming the lorry driver entirely) while telling the Labour Court that Mahadeo was solely responsible: conduct the Court likened to fraud on the court and impermissible "approbating and reprobating." It upheld the High Court's exercise of review jurisdiction, holding the MACT written statement and award were highly relevant documents Mahadeo could not earlier have produced. On back wages, the Court applied the settled principle that full back wages is the normal rule for illegal/wrongful termination but modified the High Court's award of 100% back wages down to 75%, noting that Mahadeo admitted to some interim "badli" (substitute) daily-wage work of unspecified earnings.

Lesson Learnt

An employer cannot take one factual position in one legal proceeding to avoid liability and a contradictory position in another to justify dismissing an employee. Courts treat such inconsistency as a fraud on the process, and it can cost the employer heavily in back wages and reinstatement benefits.

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

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