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Ram Manohar Lohia Joint Hospital & Ors. v. Munna Prasad Saini & Anr.

Civil Appeal · 2021 INSC 509Decided 20 Sept 2021
Civil Appeal No. 5810 of 2021
Justice R. Subhash Reddy · Justice Sanjiv Khanna

Background

A ward boy who worked at a government hospital in Lucknow from 2003 to 2005 was found by the Labour Court, based on attendance registers, salary records and other documents, to be an employee of the hospital itself, not of a security/contracting agency the hospital claimed had supplied him. The Labour Court ordered his reinstatement with back wages for a period of unemployment, and the High Court upheld this. The hospital appealed to the Supreme Court.

Decision Breakdown

The Supreme Court upheld the factual finding that the worker was indeed the hospital's employee, declining to disturb the Labour Court's assessment of the documentary evidence. However, on the question of relief, the Court held that since the worker was only ever a contractual (not permanent) employee in a government hospital where regular posts require State Government approval and formal procedure, reinstatement was not the appropriate remedy. Applying its own precedent that reinstatement is not automatic for daily-wage/contractual terminations found illegal on procedural grounds, the Court set aside the reinstatement order and substituted it with a lump-sum compensation of Rs. 10,00,000.

Lesson Learnt

Even where a wrongful termination is proven, courts may decline to order reinstatement for contractual or daily-wage workers, especially in government institutions bound by formal recruitment rules, and instead award monetary compensation as full justice.

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

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