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A registered trade union, under the Indian Trade Union Act, is entitled to
The immunities enjoyed by a trade union can be of two types: civil immunity
and criminal immunity. These immunities provide the members and officers of
registered trade unions relaxation against various civil and criminal liabilities.
The basic rights of trade unions rest on these immunities, without which the
The office bearers, members of a registered trade union and a registered trade
and Section 18(2) of the Trade Union Act. As per the provisions of Section
18(2) of the Act, a registered trade union enjoys immunity from civil suits and
liability in case of tortious activity i.e. criminal or illegal wrong act done in
knowledge of the union executive of the trade union or against the rules laid
down by it.
However, the right of a trade union to be protected from civil suits and
Nonetheless, such an act must not be illegal. If an act is executed for a reason
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other than promotion of a trade dispute, the immunity from civil suits is not
trade dispute involves violent or illegal means, the trade union or its members
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THE DIFFERENCE BETWEEN CRIMINAL AND CIVIL
LIABILITY
CRIMINAL LIABILITY
magistrate, or a judge and jury in the Crown Court. The basic assumption in
criminal liability is that there is both a mental element and physical element to
the offence.
and "appropriating" which is a physical act. The burden of proof for criminal
offences in relation to, for example, road traffic law or environmental law have
been so structured that the "mental element" is in fact not required for a
obtain convictions which otherwise would be very difficult. The penalties for
punishments.
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CIVIL LIABILITY
Civil liability gives a person rights to obtain redress from another person e.g.
the ability to sue for damages for personal injury. There is also the right to
obtain an injunction. For there to be an award of damages, the injured party has
financial loss.
The burden of proof is "the balance of probability" which is much lower than
If there has been a relevant criminal conviction in a particular matter, then the
burden of proof in any related civil action is reversed, so that the defendant has
company for breach of health and safety legislation, followed by the injured
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CRIMINAL CONSPIRACY IN TRADE DISPUTES
punishment under sub-section (2) of section 120B Indian Penal Code (45 of
1860), in respect of any agreement made between the members for the
office bearers of a registered trade union is partial in the sense that the immunity
is available only in respect of agreements made between the members for the
offence, no immunity can be claimed. The effect of section 17 of the act is that
individual, furtherance of their trade disputes, such as to declare strike and for
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The offence of criminal conspiracy under section 120-A is a distinct offence
introduced for the first time in1913 in chapter V-A of the penal code. The very
that all the conspirators must know each and every detail of the conspiracy as
along as they are co-participators in the main object of the conspiracy. There
may be so many devices and techniques adopted to achieve the common goal of
the conspiracy and there may be division of to achieve the common goal of the
with one object to achieve the real end of which every collaborator must be
aware and in which each one of them must be interested. There must be unity of
object or purpose but there may be plurality of means sometimes even unknown
to one another, amongst the conspirators. In achieving the goal several offences
may be committed by some of the conspirators. The only relevant factor is that
all means adopted and illegal acts done must be and purported to be in
furtherance of the object of the conspiracy even though there may be sometimes
others it will not affect the culpability of those others when they are associated
1
Yash pal mittal v state of Punjab (1977) 4 SCC 540
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Under section 120-B there must be an agreement between two or more persons
the doing of an act which is legal, in an illegal way there should also be
There must be a meeting of minds in the doing of the illegal act or the doing of
conspiracy or the plot they cannot held to be conspirators, though they may be
cause to be done an act which is itself an offence, in which case no overt act
remain in agreement and as long as they are acting in accord and in furtherance
guilty of criminal conspiracy, though the illegal act agreed to be done has not
been done. So too, it is not an ingredient of the offence that all the parties
member of acts. Where the accused are charged with having conspired to do
2
Lennart Schussler v Director of Enforcement, (1970) 1 SCC 152
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three categories of illegal acts, the mere fact that all of them could not be
considering the question whether the offence of conspiracy has been committed.
They are all guilty of the offence of conspiracy to do illegal acts though for
though the illegal act pursuant to the agreement was not performed.4
In West India Steel Company Ltd v. Azeez5 a trade union leader obstructed
work in the factory for five hours protesting against deputation of workman to
work another section. It was held that a worker inside a factory is bound to obey
the reasonable instruction given by his superiors and carry out the duties
assigned to him. A trade union leader has no right in law to share managerial
about the manner in which they have to do their work or discharge their duties.
A trade union can espouse the cause of the workers and can resort to lawful
agitation for conducting their rights but officials of trade union are not entitled
establishment.
3
Major E.G. Barsay v State of Bombay, (1962) 2 SCR 195
4
Kehar Singh v State of State ( Delhi Admin ) 1988 3 SCC 609
5
(1990) II L.L.J 133 (kerela).
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LOCKOUT
Acc to Industrial Disputes Act 1947, lock-out means the temporary closing
A lockout may happen for several reasons. When only part of a trade union
For example, if a group of the workers strike so that the work of the rest of
declare a lockout until the workers end the strike. Another case in which an
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PICKETING
When workers are dissuaded from work by stationing certain men at the
involve any violence, it is perfectly legal. Pickets are workers who are on
drawing public attention towards the fact that there is a dispute between the
to stop or persuade workers not to go to work, to tell the public about the
GHERAO
from leaving the industrial establishment premises by workers who block the
exit gates by forming human barricades. The workers may gherao the
members of the management by blocking their exits and forcing them to stay
inside their cabins. The main object of gherao is to inflict physical and
mental torture to the person being gheraoed and hence this weapon disturbs
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the industrial peace to a great extent.
have the right to strike and commit actions in furtherance of trade disputes
for which they cannot be held civilly or criminally liable, this exemption
does not extend to situations where they can be afforded immunity from any
In Jay Engineering Works Ltd vs State of West Bengal8, the Calcutta High
Court reiterated this view and stated that the exemptions granted under s. 17 of
peaceful strike such as cessation of work with the object of enforcing their
claims. Such strikes must be peaceful and never violent and there is no
the working hours is permissible when it is peaceful and does not violate the
offence then such exemption is lost. Thus where the workmen resort to
6
A.I.R 1935 Nag 149
7
Section 40 of the IPC defines Offence as an act punishable by the Code. An Offence takes place in two ways,
either by commission of an act or by omission of an act.
8
AIR 1968 Cal 407
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confinement of persons, criminal trespass or where it becomes violent or
In this case the court defined gherao as a “physical blockade of a target either
workers, without regard for the machinery provided for redressal of complaints
as provided for by the law, and hence it took the view is that a gherao is illegal
prosecution.
decided upon a "sit down strike" by taking over and holding two of the
employees. Work stopped and the remainder of the plant also ceased operation.
The superintendent accompanied by the police went to each of the buildings and
loudly announced that the men who had seized the plant were discharged for
seizure and occupation of the buildings. The men took no heed of it and
continued to occupy the building and the respondent obtained from Court an
injunction order requiring the men to surrender the premises, but the men
refused to obey the orders and writs of attachment were issued by the court
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There was a pitched battle, and at first the men successfully resisted the Sheriff,
but ultimately were over-powered and removed. Most of them were eventually
Section 17 of the Indian Trade Union, Act 1926. is based on Section 3 of the
Section 5(3) of the Trade Disputes Act 1906. With regard to this provision.
"My Lords, I am indeed conscious of the fact that the view upon the supposed
authority than that of Lord Lereburn. who was Lord Chancellor at the time of
the passing of the Trade Disputes Act, 1906. I have in mind the celebrated
passage in his speech in Con-way v. Wade,11 'It is clear that, if there be threats
of violence, this Section gives no protection for then there is some other ground
of action besides the ground that it induces some other person to break a
no breach of contract, and yet there is an interference with the trade, business,
or employment of some other person, or with the right of some other person to
9
(1938) 306 US 240 = 83 Law Ed 627
10
1964 AC 1129 at page 1191
11
1909 AC 506
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dispose of his capital or his labour as he wills, there again there is perhaps a
It will be noticed however that both Sections 17 and 18 of the Trade Union Act
1926 tall far short of the rights conferred by the English Acts. The common
molestation.
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SECTION 18
Immunity from civil suits in certain cases- section 18 of the Trade Unions Act
deals with the immunity from civil proceedings afforded to a registered Trade
Union, and to its members or office bearers. A person is liable in torts for
employer and the employee. But a registered Trade Union, its members or
office bearers are protected from being sued for inducing a person to break his
Section 18(1) of the Act provides that no suit or other legal proceeding shall be
maintainable in any civil court against any registered Trade Union or any office
on the ground only that such act induces some other person to break a contract
to employment of some other person or with the right of some other person to
on the word “only” which means the protection is limited only to the grounds of
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office bearers shall be liable for any act not covered by this clause. There shall
Section 18(2) of the Act provides that a registered Trade union shall not be
liable in any suit or other legal proceeding in any civil court in respect of any
of the trade union if it is proved that such person acted without the knowledge
of, or contrary to, express instructions given by the executive of the trade union.
It was held in the case of Ram Singh and othrs v. M/S Ashoka Iron Foundary
and othrs12 that a suit for personal injunction restraining the workmen from
Therefore, where the court has barred the workmen from holding meeting,
dharna and interfering in the rights of a company, such a restraint does not
curtail the just trade union activities of the workers. It cannot be construed as
unjust and the workmen are at liberty to carry on legitimate trade union
activities peacefully.
strike, per se would not be an actionable wrong. Further the office bearers, and
the members of a registered trade union are immune against legal proceedings
linked with the strike of the workmen by the provisions of Section 18 of the
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Rohtas Industries Staff Union v. State of Bihar14, is the leading case on this
section. In this case the question for determination was, whether the employers
have any right to claim damages against the employee participating in an illegal
strike and thereby causing loss of production and business. Ramaswami, C.J.
manifest that the overriding purpose of the Act is the benefit of the community
and not the benefit of the employees or the employers. It is true that section 24 15
illegal strike. But it is manifest that if there is a breach of this statutory duty on
the part of the part of the employees, the employer has no right of civil action
against the employees in default apart from the statutory penalty provided by
section 26(1) of the Industrial Disputes Act, 1947. Similarly if the employer
by section 24 of the Industrial Disputes Act, 1947 but the employees have no
right of civil action. The exclusive remedy open to reasons I hold that the duties
imposed by sections 26(2) of the act. For these reasons I hold that the duties
14
A.I.R 1963 Pat. 170
15
Section 24 of the Industrial Disputes Act, 1947- Illegal strikes and lock- outs.-
(1)A strike or a lock- out shall be illegal if--(i) it is commenced or declared in contravention of section 22 or
section 23; or (ii) it is continued in contravention of an order made under sub- section (3) of section 10 1[ or
sub- section (4A) of section 10A].
(2) Where a strike or lock- out in pursuance of an industrial dispute has already commenced and is in existence
at the time of the reference of the dispute to a Board, 1[ an arbitrator, a] 2[ Labour Court, Tribunal or National
Tribunal], the continuance of such strike or lock- out shall not be deemed to be illegal, provided that such strike
or lock- out was not at its commencement in contravention of the provisions of this Act or the continuance
thereof was not prohibited under sub- section (3) of section 10 1[ or sub- section (4A) of section 10A].
(3) A lock- out declared in consequence of an illegal strike or a strike declared in consequence of an illegal lock-
out shall not be deemed to be illegal.
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owed by sections 22,23 and 24 of the Industrial Disputes act are statutory duties
owed by the employees, not to the employers concerned but duties owed of the
26(1) of the act. It follows, therefore, that the employers have no right of civil
In the above case it was further held that the striking workmen are not prevented
Act,1962 mainly because the strike is illegal under section 24(1) of the
It is the duty of the court to see that the strike is undertaken in contemplation or
furtherance of” is not defined. For any act to be done in furtherance of a dispute,
the dispute must be present or imminent and whether a trade dispute is actual,
16
Rohtas Industries Staff Union v. State of Bihar, A.I.R 1963 Pat. 170
17
Ibid.
18
Conway v. Wade, 1909 A.C. 506
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In Simpson& Group Companies Workers & Staff Union v. Amco Batteries
Ltd.19, it was held that physical interference or duress with free movement of
obstructing the free movement of cars, vehicles and lorries carrying raw
materials, intermediaries, end products into and out of the factory premises
could not be justified as a trade union right or a fundamental right under Article
1920 of the constitution of India. Immunity under section 18 of the Trade Union
Act does not extend to the above activities. Right to picket is a very intangible
one and is limited by the equal right of others to go about their lawful affairs
oral and visual methods and it does not extend to physical obstruction of a
vehicle or person.
19
(1992) I L.L.J. 266 (Karn)
20
19. Protection of certain rights regarding freedom of speech etc
(1) All citizens shall have the right
(a) to freedom of speech and expression;
(b) to assemble peaceably and without arms;
(c) to form associations or unions;
(d) to move freely throughout the territory of India;
(e) to reside and settle in any part of the territory of India; and
(f) omitted
(g) to practise any profession, or to carry on any occupation, trade or business
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It was held in Reserve Bank Of India v. Ashis Kusum21 , that in order to secure
other provisions of law. It was further held that the movement or agitation or
In Sri Ram Vilas Service Ltd. and othrs v. Simpson and Group Companies
Workers Union and othrs24, it was held that if cessation of work is the result of
themselves or through their customers are permitted to remove the goods either
permitted to remove the goods by themselves without the aid of the labour that
21
(1969) 73 Cal. W.N. 388.
22
Ibid.
23
Ibid.
24
(1979) II LLJ 284 (Mad.)
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would tantamount to rendering the strike ineffective and to achieve that purpose
In Western India Cine Employee’s v. Filmalaya Pvt. Ltd.,25 the union made
the employment of the Filmaya Pvt. Ltd. and they were shown as temporary
bodies and associations of Cine Artists, technicians and workers requiring them
to issue directions to their members not to report for shooting work at the studio
standstill. The Plaintiffs, therefore, filed a suit requesting the civil court to grant
It was held by the High Court in appeal that a trade dispute existed and the trial
court was wrong in coming to the conclusion that there was no existing trade
dispute. Further, issuing directions to its own members not to co-operate with
them freedom of choice by any unlawful and violent means. What acts of a
trade union are protected under section 18 depends on the facts of each case. It
was further held that the acts of a trade union such as using abusive language
towards the employers, their staff and visitors are subject to other laws of the
25
(1981) II LLJ 393
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land. A trade union is entitled to carry out its legitimate trade union activities
Emplyees Union and othrs,26 that dharnas and demonstrations, though they
may cause inconvenience to the management, are permissible even inside the
industrial establishment within the working hours so long as they do not turn
orders of Civil Court and they would be covered by section 18 of the Act.
Union and othrs,27 the High Court decreed a suit of the bank by restraining the
defendant union from holding demonstrations etc. within a radius of 100 metres
from the suit property i.e, Bank building. It further observed that the freedom of
speech and right to form association granted by the constitution did not confer a
another. As for the immunity of Trade Union under section 18 of the Trade
26
(1994) II L.L.J. 912 (Guj.)
27
(2001) I L.L.J. 1009 (Del.)
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concerned, it is protected only by allowing demonstrations at a distance of 50 or
In the case of West India Steel Co. Ltd. v. Azeez28, it was held that Immunity to
In the case of U.P. Rajya Setu Nigam Sanyukt Karmachari Sangh v. U.P.
State Bridge Corporation29, it was held that The Act has not provided that
Section 18 of the Trade Unions Act did not excuse trespass into another's
"It does not appear to me in the first instance that Section 18 of Act 16 of 1926
is any bar to the present suit. If the section is carefully read and if the object of
28
1990 LLR 142 (Ker).
29
2000 LLR 151 (All).
30
AIR 1939 Sind 256
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employment between employer and employee, the section provides that a
and significant words in the section are "on the ground only"
The section does not afford immunity to a trade union or to an officer thereof
for an act of deliberate trespass" The word 'strike' has been defined in the
common under- standing, of any number of persons who are or have been so
which aids them in any concerted movement to improve their position vis-a-vis
the management. Mere absence from work does not amount to a strike. There
should be evidence to show that the absence was the result of some concert
between the workmen, that they would not continue to work. Strike, when it is
lawful is a legitimate weapon in the hands of worker. A gherao may or may not
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RECENT CASES
In this case, the writ petitioner had moved the civil Court and after hearing both
the parties, the civil Court had come to the conclusion that prima facie the writ
petitioner is entitled for an order of injunction preventing the 4th respondent and
its members from involving in violent activities or gathering in large numbers,
preventing the workers, who are willing to work either to enter into or to come
out of the premises or preventing the writ petitioner from allowing the materials
to be taken out and taken inside the premises and such injunction has been
granted against the 4th respondent upto 100 meters and as the said order of
injunction is in force, it is not open to the 4th respondent and its members to
violate the said order in the guise of immunity under the Trade Unions
Act,1926.
In view of the above settled position of law, I do not think that the facts of this
case will be covered under Section 18 of the Trade Unions Act,1926. Section
18(1) of the Trade Unions Act,1926 certainly prohibits the employer from
breaking the contract of employment and it gives immunity to an office bearer
in respect of the act done by him. When the employer attempts to divide the
striking workers, which is lawful, it is certainly open to the 4th respondent
Union and its members to approach the Inspector of Factories or raise an
industrial dispute by treating the same as unfair labour practice, etc. and the
immunity granted under Section 18(1) of the Act cannot mean to say that the
Union must be permitted to achieve its object by resorting to the method which
are not permitted in law.
31
W.P.No.36345 of 2007
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In view of the above said facts and legal position, I am of the considered view
that the writ petitioner must be granted police protection in the light of the order
of injunction granted on 09.06.2007 in I.A.No.100 of 2007 in O.S.No.54 of
2007, which was made absolute on 21.11.2007, to perform its legal obligations,
but at the same time, with liberty to the 4th respondent Union to approach the
appropriate forum for redressal of its grievance regarding the alleged
employment of trainees/apprentices on regular basis by the writ petitioner. In
view of the same, the writ petition stands ordered on the above terms.
the respondents assembled at the main entrance of the company and started to
obstruct the ingress and egress of the loyal workers, foreign customers and
visitors of the company. They had also warned the officials that they would
obstruct the vehicle transport and apprehending that the respondents might
resort to their unlawful attempts the petitioner company filed the suit along with
the three I.As for the interim reliefs as stated above.
(i) There is no evidence or any materials to show that an illegal strike was
conducted on 20.1.2006;
32
CRP (PD) Nos.1036 to 1038 of 2007
26 | P a g e
company which is contravention of immunity provided under Section 18 of the
Trade Unions Act, 1926;
(iii)There is no evidence to show that the respondents had in fact prevented the
petitioner's employees or vehicles from moving in and out of the premises and
on mere apprehension the relief cannot be granted.
But a perusal of the order would show that the trial court under the guise of
equity, establishment of prima facie case, and existence of balance of
convenience has gone to the extent of deciding whether there was a legal or
illegal strike, whether the activities of the respondents are immuned under
Section 18 of the Trade Union Act an thus took the role of the Presiding Officer
of an Industrial Tribunal.
The workers may resort to peaceful picketing i.e., the marching to and from
before the premises of an establishment. They may be accompanied by the
carrying and display of sign boards, placards or banners bearing statements in
connection with the dispute. They may also request politely the employees not
to assist in the running of the business and ask the customers not to patronise
that establishment. Such acts would constitute peaceful picketing and are
protected under Section 18. The demonstration may cause inconvenience and
embarrassment to the employer. It may be intended to bring pressure on the
management to concede to the workers' demands. But such demonstration is
protected so long as it is peaceful and does not turn violent.
27 | P a g e
getting out of the same till the disposal of the suit or the conciliation
proceedings, whichever is earlier.
The vehicle if operated in the said route would have fetched Rs.500/- per day
after meeting all the expenses. The bus was recovered on 4- 9-1988 and the
plaintiff made an attempt to operate the vehicle in the respective route. This was
obstructed by the defendants. So the plaintiff along with his father filed O.P.
No. 7139 of 1988 before the High Court for police protection. Plaintiff could
resume service only after the High Court's order was obtained. Under the above
circumstances plaintiff caused a lawyer notice to the defendants claiming
33
O R D E R 26/06/2008
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damages since there was no favourable response to the lawyer notice the suit
has been instituted claiming recovery of Rs.37,000/- byway of damages due to
non-operation of the bus KLM. The defendants filed written statement
contending that the bus owned by the plaintiff and the bus owned by his father
Alavikutty are all managed by the plaintiff and his father jointly under the name
and style K.V.Brothers. At the alleged time of stealing of the bus there were
industrial disputes pending between his father and the defendants and also
between the plaintiff and the trade union in which the defendants are members.
Plaintiff denied employment to one A.Soman, who is the driver of bus KLM
324 by making false allegations against him. The defendants and Soman are
members of the same trade union. On 27-8-1988 the defendants did nothing to
bus No.KLM
The bus was lying idle at the Mofussil Bus Stand, Calicut following the strike
of workers. The petition before the C.J.M. Court was filed without any bona
fides. Driver Beerankoya and conductor Saidalavi mentioned in the plaint are
people who are in inimical terms with the members of the trade union to which
the defendants belong on political as well as personal grounds. The plaintiff
deliberately kept away from five conciliation meetings convened by the labour
authorities was only trying to create evidence for the industrial disputes against
the union by filing petition before the C.J.M. Court. Bus KLM 324 was never
recovered from the defendants as alleged in the plaint. Defendants have not
taken possession of bus KLM 324 from the custody of the plaintiff. The
allegations of obstruction caused by the defendants to the operation of the
service after 4-9-1988 is denied. The writ petition was disposed of 30-1-1989 by
the High Court with the direction to the authorities that police protection is to be
given to the petitioner only if they are employing their regular employees whose
names are shown in the pay rolls as pm 27-8-1988. Denial of employment to
regular employees was the grievance of the defendants and their union against
the plaintiff and his father. The suit is only to be dismissed with costs.
On the above pleadings the learned Sub Judge formulated the following three
issues.
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1. Whether the bus KLM324 was stolen by these defendants on 27-8-88 and
whether the operation of the bus in the route was stopped from 4-9-88 onwards
due to the obstruction caused by the defendants as alleged in the plaint?
Additional issue No.4 was considered in the context of section 18(1) of the
Trade Union Act and it was found that the suit is not maintainable in view of
that provision.
Sri.T.G.Rajendran, learned counsel for the appellant and Sri.Titus Mani, learned
counsel for the respondents addressed me. It was very extensive submissions
which were addressed by Sri.T.G.Rajendran who draw my attention to Exts.A1
certified copy of the petition filed before the C.J.M. Court, Ext.A2 seizure
mahazar in respect of the bus, report submitted by the A.S.I. before the C.J.M.
Court, Ext.A3 order of the Division Bench in the police protection case and also
to oral evidence addressed before the court below by Pws.1 and 2 and DW-1. It
cannot be said that the submissions of Mr.Rajendran assailing the correctness of
the finding entered by the court below on issue Nos.1 and 2 were without any
appeal. But at the same time I am of the view that it is a correct finding which
was entered by the learned Subordinate Judge on additional issue No.4. Section
18(1) of the Trade Unions Act 1926 which is quoted by the learned Subordinate
30 | P a g e
Judge in the judgment itself is a complete bar for suits and other legal
proceedings in any civil court against any registered trade union or any office
bearer or member of the trade union in respect of any act done in contemplation
or furtherance of a trade dispute to which a member of the trade union is a party
on the ground only that such act induces some other person to break a contract
of employment or that t is in interference with the trade, business or
employment of some other person or with the right of some other person to
dispose of his capital or of his labour as he wills. It is the definite case of the
defendant that they are members of a registered trade union. The evidence will
reveal that the alleged strike arose due to the denial of employment to a regular
employee and member of the said trade union by name Soman. PW-2 himself
submitted that after purchase of the bus the plaintiff has denied employment to
some of the old employees and appointed new ones. Of course the argument of
the plaintiff was that denial of employment and labour problem was regarding
the bus operated by father of the plaintiff under the name and style
K.V.Brothers and that the plaintiff is operating his business under the name and
style K.V.Transport and that in the plaintiff's bus there was no labour problem
and that defendants obstructed plying of bus by the plaintiff so that the labour
dispute between plaintiff's father and his employees will come to an end. It is in
evidence that the plaintiff has gone over to the labour officer at least five times.
The disputes certainly involves a registered trade union and its members. I do
not find any reason for varying the learned Subordinate Judge's finding that the
suit is not maintainable. The finding of the court below on additional issue No.4
is confirmed. The appeal is dismissed on that reason without examining the
merits of the findings entered by the court below on the other issues, since the
same is unnecessary.
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BIBLIOGRAPHY
Lucknow.
S.N. Mishra: Labour and Industrial Laws, 26th edition, 2011, Central
www.indiankanoon.com
www.lawnotes.com
www.lawyersclub.com
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A PROJECT ON
SUBMITTED TO
PAPER II
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ACKNOWLEDGEMENT
Thank you
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