The Supreme Court of India emphasized the principle of fairness in labour practices in its judgment dated March 12, 2024, in the case of Mahanadi Coalfields Ltd. versus Brajrajnagar Coal Mines Workers’ Union (Civil Appeal No(s). 4092-4093/2024). The case pertains to the regularisation of contract labourers.

Key Points of the Judgment:

  1. Background: Mahanadi Coalfields Ltd., a subsidiary of Coal India Ltd., had contracted a tender for transporting crushed coal from 1984 to 1994. The contractor employed workmen for this task. The respondent-union represented these workers, demanding their permanent status based on clauses of the National Coal Wage Agreement-IV, which discourage contract labor for permanent and perennial jobs.
  2. Initial Settlement and Tribunal’s Decision: A settlement in 1997 under the Industrial Disputes (Central) Rules 1957 regularized 19 out of 32 workers. The matter was later referred to an Industrial Tribunal, which in 2002 directed the regularization of the remaining 13 workers, finding their work perennial and regular.
  3. Proceedings in High Court: The High Court upheld the Tribunal’s decision. A review petition filed by the appellant (Mahanadi Coalfields Ltd.) was dismissed.
  4. Supreme Court’s Analysis: The Supreme Court rejected the appellant’s contention that the settlement was final and binding. It held that the Tribunal was justified in its award and that the work nature of the 13 workers was similar to that of the 19 regularized employees.
  5. Supreme Court’s Conclusion: The Court found no merit in the appeals by the appellant. It was ruled that the 13 workers’ denial of regularization was unjustified and they are entitled to back wages from the date of the Tribunal’s decision (May 23, 2002).
  6. Final Judgment: The Supreme Court dismissed the appeals with the direction that the concerned workers shall be entitled to back wages effective from May 23, 2002. There was no order as to costs.

The judgment signifies the court’s recognition of the rights of contract laborers to be regularized in cases where their work is of a perennial and regular nature, aligning with the principles of fair labor practices.

Mahanadi Coalfields Ltd. versus Brajrajnagar Coal Mines Workers’ Union (Civil Appeal No(s). 4092-4093/2024)


Sanjiv Narang Adv. is an Advocate on Record in the Supreme Court of India. His qualifications include an LLB from University of Delhi and a Masters degree in Personnel Management from Panjab University,Chandigarh.In his more than 3 decades of experience, he has practiced law at the District, High Court and Supreme Court levels.He also has more than a decade of experience in the field of Management. He is the author of two books namely Laws for Women in India and Innovation, Why What and How.