Summary
Industrial references challenging reduction of the retirement age were barred because the same dispute and incidental issues had already been finally decided on merits between the employer and unions in earlier writ proceedings. The Supreme Court reaffirmed that res judicata, including its general application to industrial adjudication, prevented the State and Labour Court from reopening the issue. It restored the Labour Court awards and displaced the High Court’s later grant of partial wages.
Issues
- Whether res judicata applied to industrial references following a final merits decision in writ proceedings.
- Whether the State and Labour Court could reopen the retirement-age dispute.
- Whether the subsequent merits award could survive.
Held
- Although the entire Civil Procedure Code does not govern industrial adjudication, the general principles of res judicata apply. A competent court’s final merits decision between the parties cannot be reopened through a later industrial reference. (¶ 23–27)
- The unions had challenged the reduction from sixty to fifty-eight in earlier writ petitions and appeals, and that litigation had concluded adversely to them. The retirement-age issue and its incidental questions had therefore attained finality. (¶ 28–30)
- The State lacked jurisdiction to refer the same issues for fresh adjudication, and the Labour Court could not entertain them on merits. Its awards declining to reopen the dispute were correct. (¶ 31–32)
- With the references barred, reconsideration of the substantive retirement-age dispute was neither necessary nor permissible. The High Court’s later interference with the awards could not stand. (¶ 32–34)
Result
Employer’s appeals allowed. Impugned High Court order set aside and Labour Court awards restored; subsequent partial-wage relief displaced.