Summary
The Supreme Court upheld relief treating the cooperative canteen’s workers as Chennai Port Trust employees with the attendant benefits. Undisputed facts established the Trust’s administrative and financial control, provision of premises and utilities, reimbursement of costs and the canteen’s integration with port operations. Indian Petrochemicals governed the materially similar circumstances. The Court rejected relegation to industrial adjudication after both High Court Benches had decided the merits on facts requiring no trial.
Issues
- Whether undisputed control and integration facts justified treating canteen workers as Port Trust employees.
- Whether the workers should have been relegated to the Industrial Tribunal instead of obtaining writ relief.
Held
- The detailed assertions establishing the Trust’s control were not specifically denied. They included approval of canteen rules, Trust nominees in management, auditing powers, free premises and utilities, financial control and reimbursement of staff and operating costs. (¶¶ 7, 14, 15)
- The canteen met the needs of a sprawling port operating round the clock, including delivery of food to work locations. Its role and the Trust’s control and support closely matched the material facts in Indian Petrochemicals. No relevant factual distinction was shown. (¶¶ 13, 14, 15, 16, 17, 18)
- On those undisputed facts and documents, the High Court properly granted the workers’ claim to treatment as regular Port Trust employees and associated monetary and service benefits. The ruling rested on the particular relationship proved, rather than a rule that every cooperative canteen creates such employment. (¶¶ 5, 8, 12, 15, 17, 18, 19)
- The alternative-forum objection did not warrant reversal after the writ and appellate courts had adjudicated the merits. Most importantly, the undisputed record required no trial of contested facts, so referral to industrial adjudication was unnecessary here. (¶¶ 20, 21, 22)
Result
Port Trust’s appeal dismissed. High Court relief recognising the canteen workers as Port Trust employees with attendant benefits upheld.