ACC Rajanka Lime Stone Quarries v. Registrar (1958)

Workers formed a union and applied for registration. The Registrar did nothing for weeks. The High Court said: registration must be handled in a reasonable time. If the Registrar sleeps over the file, the Court can issue a writ of mandamus to make the Registrar decide.

• Core idea: Delay violates the spirit of Article 19(1)(c); courts can compel action under Article 226.
• Outcome: Registrar was directed to act promptly; the union was registered.

• Does the Registrar have a duty to deal with a union registration within a reasonable time?
• Can the High Court issue mandamus if the Registrar takes no action for months?

• Registrar must act on registration applications within a reasonable time.
• Mandamus can be issued under Article 226 if the Registrar sits idle—particularly beyond about three months.
• Unreasonable delay burdens the Article 19(1)(c) right to form unions.

Administrative discretion cannot mean indefinite delay. Because union formation is a protected freedom, the Registrar must act reasonably fast; courts can compel action by mandamus.

• Prevents red-tape from blocking union rights.
• Sets a practical yardstick for “reasonable time.”
• Shows how Article 226 protects fundamental freedoms in practice.

1. Registrar must process union registration without undue delay.
2. Mandamus can force a decision when files stagnate.
3. Delays can burden Article 19(1)(c) rights.

Mnemonic: “D-R-M” — Delay barred, Registrar must act, Mandamus if not.

1. Watch the clock: Is the file idle for months?
2. Tie to rights: Does the delay hurt union formation?
3. Seek relief: Ask the High Court for mandamus.

Mandamus

A High Court order commanding a public authority to perform a legal duty.

Reasonable Time

No fixed number of days, but months of inaction can be unreasonable.

Article 19(1)(c)

Fundamental right to form associations or unions.