Sunday, October 13, 2013

LABOUR LAW

Evaluation of Time Spent during Period of Suspension from Job

Introduction and Fact in Issue
The Letters Patents Appeal[1] in Delhi High Court In General Manager, Canara Bank vs. Kuldeep Sharma[2] directed against the judgment of the single judge in a writ petition regarding allowing the Respondent’s evaluation of “time spent” during the period of suspension. The Appellant’s contention was that the aforesaid evaluation is contrary to the judgment of the General Manager UCO bank and Anr. vs. M.Venuranaganath[3] which was applied by learned single judge to grant relief to the Respondent. The present appeal was allowed.

Fact
The writ petition of the Respondent was allowed; where as the review of the appellant was dismissed in this matter. The Respondent was an employee of Appellant. The Respondent had two sons. The wife of the youngest son died an unnatural death and the Respondent was arrested in connection to her death for an FIR registered under sections 498A/304B/302/34 read with section 3 / 4 of Dowry Prohibition Act and was placed under suspension for two years from job. Subsequently, the Respondent was granted bail by the Sessions court. Thereafter, two years later, the General Manager passed an order revoking[4] the suspension of the Respondent from the date on which he reports on duty and further, the Respondent would be paid salary and allowances as he was being paid before suspension. But   “time spent” during the period of suspension shall not be counted for any purpose i.e shall not be treated as spent on duty. The Respondent superannuated[5] the year when his suspension was revoked and the Sessions Court also acquitted him year later of all charges. In between, the Respondent made a request for release of differential salary and counting the period of suspension, as that the one that is spent on duty. However, the demand was not accepted on the ground that the same was a departmental decision then.
Impugned Judgement
The learned single judge allowed the contention of the Respondent, time period of suspension was time spent on duty. The court after scrutinizing the Canara Bank Officer Employees’ (Conduct) Regulations, 1976 (“Regulations”) held that the decision of the department to not consider the period of suspension, as spent on duty was arbitrary. The single judge relied upon the judgment General Manager UCO bank and Anr. vs. M.Venuranaganath  and allowed the relief to the Respondent.

Argument of the Appellant
1.         The case of General Manager, UCO Bank (supra) does not support the case of the respondent at all. But, on the contrary, supports the case of the appellant.

2.         The Regulation 15 of the said Regulations reads as under: -
“15. Pay, allowances and treatment of service on termination of suspension:
(1) Where the competent authority holds that the officer employee has been fully exonerated or that the suspension was unjustifiable, the officer employee concerned shall be granted the full pay to which he would have been entitled, had he not been suspended, together with any allowance of which he was in receipt immediately prior to his suspension, or may have been sanctioned subsequently and made applicable to all officer employees.

(2) In all cases other than those referred to in sub-regulation (1), the officer employee shall be granted such proportion of pay and allowances as the Competent Authority may direct:

3.         Regulation 15 by itself, it is abundantly clear that the respondent cannot get the benefit under Regulation 15(1) as his case is not of a departmental proceeding, but of a criminal case. The respondent’s case falls under Regulation 15(2) and, if that be so, the respondent is only entitled to be granted such proportion of pay and allowances as the competent authority may direct. The respondent is not entitled to the grant of full pay to which he would have been entitled had he not been suspended. That is only possible under Regulation 15(1) which does not apply to the respondent’s case.

4.         We may also point out that Regulation 15(3) deals with two situations; one, where the case falls under sub-Regulation (1) and; two, where the case falls under sub-Regulation (2). Since the respondent’s case falls under Regulation 15(2), it would be Regulation 15(3)(b) which would apply. According to that sub-Regulation the period of absence from duty shall not be treated as a period “spent on duty” unless the competent authority specifically directs, for reasons to be recorded in writing, that it shall be so treated for any specific purpose. In other words, normally, the period of absence from duty in such cases is not to be treated as a period “spent on duty”. It is only in cases where the competent authority specifically directs that such period of suspension should be treated as having been “spent on duty” that the competent authority is required to give reasons in writing. No reasons are necessary when the period of suspension in cases falling under sub-Regulation 15(2) is treated as “not spent on duty”

Judgment Relied
The Delhi High Court relied upon this judgment of the Supreme Court Union Bank of India vs. K.V Jankiraman & Ors.[6]. In this case, Supreme Court has held that the principle of “No work no pay” is not applicable to cases where the employee is willing to work is kept away from by the authorities for no fault. The apex court further held that, when an employee is completely exonerated, meaning thereby that he is not found blameworthy in the least and is not visited with the penalty even of censure, he has to be given the benefit of the salary of the higher post along with the other benefits from the date on which he would have normally been promoted but for the disciplinary/criminal proceedings. However, there may be cases where the proceedings, whether disciplinary or criminal, are, for example, delayed at the instance of the employee or the clearance in the disciplinary proceedings or acquittal in the criminal proceedings is with benefit of doubt or on account of non-availability of evidence due to the acts attributable to the employee etc. In such circumstances, the concerned authorities must be vested with the power to decide, whether the employee at all deserves any salary for the intervening period and if he does, the extent to which he deserves it. However, whether the officer concerned will be entitled to any arrears of pay for the period of notional promotion preceding the date of actual promotion, and if so to what extent, will bed decided by the concerned authority by taking into consideration all the facts and circumstances of the disciplinary proceeding / criminal prosecution. Where the authority denies arrears of salary or part of it, it will record its reasons for doing so.

Ratio of the Judgment
The Hon’ble court while going through the above extract from the Supreme Court decision in K.V. Jankiraman (supra), held that, it is clear that the concerned authorities are to be vested with the power to decide whether an employee at all deserves any salary for the intervening period or not and if he does, then to what extent to which he is entitled. The court also observed that it would not be possible to lay down an inflexible rule that in every case when an employee is exonerated in disciplinary / criminal proceedings, he should be entitled to all salary for the intervening period and to lay down such an inflexible rule would be to undermine the discipline in the administration and jeopardize public interest.

Therefore, there was nothing wrong with the appellant deciding not to grant salary to the respondent during the period of suspension because this was in exercise of the discretion under Regulation 15(2) of the said Regulations



[1]In simple words, Letters Patent Appeal is an intra court appeal. It is an appeal before two judges of   
 same high court against judgment of single judge. Subject to minor differences in different High    
 Court Rules, normally a judgment and order passed under Art 226 of the Constitution is appealable  
 as LPA and judgment and order passed under Art 227 is not appealable under this category. 
[2] L.P.A. 771/2013; Justice Badar Durrez Ahemd and Justice V.K.Jain
[3] 2007 (13) SCC 251
[4] It means putting an end to the operation of an order.
[5] It means retirement.
[6] 1997 (4) SCC 109

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