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Person discharging managerial functions cannot be treated as a workman: Karnataka HC

Case Law Details

TaxGuru Citation
2025 taxguru.in 222
Case Name
Mphasis Limited Vs Ashok S. Narayanpur (Karnataka High Court)
Date of Judgement/Order
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Mphasis Limited Vs Ashok S. Narayanpur (Karnataka High Court)

Karnataka High Court addressed the case of Mphasis Limited versus Ashok S. Narayanpur, where the issue was whether the respondent’s role as a Project Lead in Mphasis fell under the definition of “workman” as per Section 2(s) of the Industrial Disputes Act (ID Act). The respondent had resigned from his position, but later sought reemployment, claiming that he was a “workman” and entitled to reinstatement. The Labour Court ruled in favor of the respondent, ordering reinstatement and continuity of service, but Mphasis challenged this decision.

Mphasis argued that the respondent, as a Project Lead, did not qualify as a “workman” because his duties were managerial in nature, rather than falling under manual, clerical, technical, or supervisory categories specified in the ID Act. The Court examined the respondent’s job responsibilities and concluded that his work was managerial, involving tasks such as planning, estimating, and decision-making, which did not align with the duties of a “workman.” The Court highlighted that for someone to qualify as a “workman,” the nature of their primary duties must fall within one of the seven specified classifications under the ID Act. Since the respondent’s work was managerial, the Court set aside the Labour Court’s decision, ruling that the respondent was not a “workman” and dismissing his claim for reinstatement.

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Author Info

CA Sandeep Kanoi
Qualification: CA in Job / Business
Company: Taxguru Consultancy
Location: Mumbai, Maharashtra
Articles Published: 19,778

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