Who is a ‘workman’ under Section 2(s)?

A person mainly doing manual, clerical, technical or supervisory work for hire or reward; not those in true managerial or administrative roles.

What about preliminary objections by public sector bodies?

The Court discouraged unnecessary objections and urged speedy resolution of labour disputes on merits.

What was ordered after recognising Verma as a workman?

The dismissal dispute was to be heard afresh by the Tribunal, now treating him as a workman under the ID Act.

SK Verma v. Mahesh Chandra (1983) II LLJ 429; (1983) 4 SCC 214

Q: Did the Court treat LIC Development Officers as workmen?

Yes, when their real duties are supervisory/clerical/technical and not managerial—like in S.K. Verma’s case.

Quick Summary

Main Question: Are LIC Development Officers “workmen” under Section 2(s) of the Industrial Disputes Act, 1947?

Answer: Yes—when their real duties are supervisory, clerical, or technical, and not truly managerial or administrative. The Supreme Court allowed the dispute to proceed on this basis.

Issues

Do LIC Development Officers fit the “workman” definition?
Should public sector bodies raise preliminary objections on maintainability?

Rules

A “workman” is a person employed in an industry to do manual, clerical, technical, or supervisory work for hire or reward. Those in genuine managerial or administrative roles are excluded—titles alone do not decide.

Facts (Timeline)

Simple Timeline

S.K. Verma worked as a Development Officer at LIC.

He was dismissed; raised a labour dispute claiming unfair dismissal.

LIC objected: a Development Officer is not a “workman”.

Central Government referred the dispute to the Industrial Tribunal.

Tribunal held for LIC; High Court upheld the view.

Verma moved the Supreme Court by SLP under Article 136.

Timeline for SK Verma v. Mahesh Chandra case

Arguments

LIC (Respondent)

Development Officers are not workmen.
Dispute is not maintainable under the ID Act.

Verma (Appellant)

Duties were mainly supervisory/clerical/technical, not managerial.
Hence covered by Section 2(s) as a “workman”.

Judgment

The Supreme Court recognised that Development Officers can be “workmen” when their real functions are supervisory/clerical/technical and not managerial/administrative. The Court discouraged public sector bodies from raising needless preliminary objections and directed that the dismissal issue be heard on merits, treating Verma as a workman.

Ratio Decidendi

Substance over title: Job labels do not control. Look at actual duties. If the main work is within the four heads (manual/clerical/technical/supervisory) and not managerial, Section 2(s) applies.

Why It Matters

Guides classification of Development Officers and similar roles.
Promotes speedy justice by curbing technical objections.
Strengthens the protective reach of labour law.

Key Takeaways

Role ≠ Title

Actual functions decide “workman” status.

Four Heads Test

Manual • Clerical • Technical • Supervisory.

Decide on Merits

Avoid wasteful preliminary objections.

Mnemonic + 3-Step Hook

Mnemonic: “TITLE? NO. DUTY!”

List Duties done day-to-day.
Match them with the four heads.
Exclude real managerial powers (hire/discipline).

IRAC Outline

Issue: Is a LIC Development Officer a “workman” under Section 2(s)?

Rule: Workman includes manual/clerical/technical/supervisory; excludes managerial/administrative.

Application: Verma’s duties were supervisory/clerical/technical; no real managerial powers like hiring/discipline.

Conclusion: He qualifies as a “workman”; dispute to be heard on merits.

Glossary

Section 2(s): Defines “workman” under the Industrial Disputes Act, 1947.
Supervisory Work: Overseeing tasks without full managerial powers.
Preliminary Objection: A technical challenge raised before hearing the main dispute.