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The Workmen through the Convener, FCI Labour Federation v. Ravuthar Dawood Naseem

Contempt Petition (Civil) · 2020 INSC 401Decided 19 May 2020
Contempt Petition (Civil) No. 404 of 2019
Justice A.M. Khanwilkar · Justice Dinesh Maheshwari

Background

Workers' unions had, years earlier, won Industrial Tribunal awards directing the Food Corporation of India (FCI) to "regularise and departmentalise" contract labourers at its depots in South India; these awards were upheld all the way up to the Supreme Court. The unions later filed contempt petitions alleging FCI had disobeyed these directions by regularising the workers only under its "Direct Payment System" (DPS) rather than the more favourable "Departmental Labour System" (DLS).

Decision Breakdown

The Supreme Court held that the original Tribunal awards and subsequent court orders had directed regularisation in general terms only, without specifying which of FCI's four labour systems should apply; they never mandated placement specifically in the Departmental Labour System. Since FCI had a longstanding policy (since 1973/1991) of regularising such workers under DPS, and had in fact regularised thousands of similarly placed workers that way, its conduct could not be called "wilful disobedience": the legal standard required for contempt. The Court dismissed all the contempt petitions and discharged the show-cause notices.

Lesson Learnt

Contempt of court requires proof of wilful, deliberate disobedience of a clear and specific direction; if a court order is genuinely open to more than one reasonable interpretation, a respondent's good-faith compliance under one reasonable reading will not amount to contempt, even if the petitioner wanted a different (better) outcome.

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

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