Ragini Sinha v. State of Bihar

Civil Appeal · 2019 INSC 20Decided 7 Jan 2019
Civil Appeal Nos. 7224-7225 of 2012
Justice Abhay Manohar Sapre · Justice Indu Malhotra

Background

Two agricultural workers claimed that they had worked on the appellant's land for about two years but were never paid minimum wages. They filed claims under the Minimum Wages Act, 1948, which the competent authority allowed, directing the appellant (their employer) to pay wages plus a penalty. The appellant's appeal against that order failed before the appellate authority, a single judge of the Patna High Court, and then a Division Bench of the same High Court, leading her to approach the Supreme Court.

Decision Breakdown

The Supreme Court dismissed the appeals, holding that the question of whether the workers had actually worked and for how long was a pure question of fact already concurrently decided against the appellant by two authorities, which bound the High Court. It also held the writ petitions were rightly dismissed because the two workers (necessary parties) had not been impleaded, and the appellant's belated attempt to add them was correctly rejected as too late. Examining the merits anyway, the Court found the appellant had been given a fair opportunity to defend herself and had produced no evidence of prejudice, so the penalty imposed was justified. The Court directed the appellant to pay the full amount due (the two workers having since died) to their legal heirs within three months, with a compliance report to the Court and the wage authority.

Lesson Learnt

An employer who disputes a wage claim must raise all procedural objections (such as non-joinder of necessary parties) promptly, raising them years late will not be entertained, and concurrent factual findings by lower authorities are very difficult to reopen before the Supreme Court.

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