What did the Court decide about laid-off workers and union registration?

Laid-off workers are not counted as actively employed members for registering a trade union under the Trade Unions Act, 1926.

Did the Industrial Disputes Act violate Article 19(1)(c)?

No. The Act does not stop workers from forming or joining associations, so it does not violate the freedom of association.

Is the Industrial Disputes Act against Article 14 equality?

No. The Act’s scheme is not arbitrary; it treats similar groups alike and follows a reasonable policy.

Did the Court find any basic-structure violation?

No. Regulating industrial disputes supports constitutional governance and does not harm the basic structure.

What happened to the union’s registration in this case?

It was quashed because the union lacked the required number of actively employed members.

Lohia Machines Limited v. Registrar, Trade Unions

Quick Summary

This case explains two things in simple terms:

Who counts as a “member” when a trade union applies for registration.
Whether the Industrial Disputes Act (IDA) breaks any part of the Constitution.

The Court held that laid-off workers are not “actively employed” for registration counts. The IDA remains valid and does not violate freedom of association (Article 19(1)(c)), equality (Article 14), or the basic structure of the Constitution.

Issues

Does the IDA violate the basic structure of the Constitution?
Does the IDA violate Article 19(1)(c) (freedom of association)?
Does the IDA violate Article 14 (equality)?
Can laid-off workers be counted as “employees” for trade union registration?

Rules

A union must have the required minimum of actively employed members from the establishment for registration under the Trade Unions Act, 1926.
Lay-off is temporary unemployment. The employer–employee relationship may continue, but laid-off workers are not counted as actively employed for registration head-count.

Facts (Timeline)

CASE_TITLE

Lohia Machines Limited made agricultural machinery.
A union sought registration under the Trade Unions Act, 1926.
Most union members, including office-bearers, were laid-off due to temporary closures.
The company refused recognition and collective bargaining.
The Industrial Tribunal directed recognition and bargaining.
The High Court upheld the Tribunal.
The company appealed to the Supreme Court, raising constitutional challenges to the IDA.

Timeline graphic for the Lohia Machines case

Arguments

Appellant (Company)

Union lacked the required number of actively employed members.
Orders forcing recognition were improper.
Raised constitutional doubts about the IDA.

Respondent (Union/Registrar)

Lay-off does not end the employment link.
Recognition and bargaining orders support industrial peace.
IDA is sound and constitutional.

Judgment

Held

Union Registration: Laid-off workers are not counted as actively employed for registration. The union failed the head-count. Registration quashed.
Article 19(1)(c): No violation. The IDA does not stop workers from forming or joining unions.
Article 14: No violation. The Act’s policy is reasonable, not arbitrary.
Basic Structure: No violation. The IDA supports fair dispute resolution.

Judgment illustration for the Lohia Machines case

Ratio Decidendi

For union registration, the statute looks at active employees in service at the establishment. A lay-off creates temporary unemployment, so those workers are not counted as active for the registration threshold.

Why It Matters

Clarifies who can be counted for trade union registration.
Confirms the IDA’s constitutional soundness.
Guides HR and unions during closures or layoffs.

Key Takeaways

Only actively employed members count for union registration numbers.
IDA is consistent with Articles 19(1)(c), 14, and the basic structure.
Lay-off ≠ termination, but not “active” for head-count.

Mnemonic + 3-Step Hook

Mnemonic: “A-L-I” — Active count only, Lay-off not active, IDA is valid.

Spot: Is the worker laid-off or active?
Count: Include only active employees for registration.
Check: Constitutional challenges to IDA fail.

IRAC Outline

Issue

Counting laid-off workers for registration and constitutionality of the IDA.

Rule

Trade Unions Act requires a minimum of actively employed members; lay-off ≠ active for head-count.

Application

Union’s membership was mainly laid-off workers; statutory threshold not met; constitutional objections to IDA do not succeed.

Conclusion

Union registration quashed; IDA upheld; appeal dismissed.

Glossary

Lay-off: Temporary stoppage of work; employee is not actively working.
Active Employee: Presently in service and working for the establishment.
Union Registration: Legal recognition of a trade union after meeting statutory requirements.