Designation Is Not Destiny: Supreme Court Reaffirms Who A “Workman” Really Is

In a decisive reaffirmation of settled labour law doctrine, the Supreme Court of India, in Srinibas Goradia v. Arvind Kumar Sahu & Ors. (2025 INSC 1467), by judgment dated 17 December 2025, has once again underscored that an employee’s designation is not determinative of their status as a “workman” under the Industrial Disputes Act, 1947. What is decisive, the Court held, is the dominant nature of duties actually performed, not the label attached by the employer.

The case concerned an employee who had worked for more than twelve years in a hotel establishment, discharging functions such as cashiering and front-office assistance. Following the abrupt termination of his services, the Labour Court found the termination illegal and directed reinstatement with back wages. This relief was, however, set aside by the Orissa High Court, which accepted the employer’s contention that the employee was a “manager” or “front office supervisor” and therefore excluded from the statutory definition of a workman.

The Supreme Court reversed the High Court’s view in emphatic terms. It held that the High Court had erred in placing undue reliance on designation alone, without examining the real nature and substance of the employee’s functions. Reiterating long-standing precedent, the Court stressed that an employee does not cease to be a workman merely because the employer assigns a high-sounding title. To fall outside the scope of Section 2(s) of the Act, the employee must, in fact, exercise independent supervisory or managerial powers, such as authority to appoint, discipline, or take binding decisions on behalf of the employer.

Surveying decades of jurisprudence, the Court reaffirmed core principles that continue to govern the “workman” inquiry. Incidental or occasional supervisory tasks do not alter the character of employment. Clerical or operational duties remain workman functions even when accompanied by limited oversight responsibilities. Most importantly, employers cannot circumvent labour law protections by cosmetic rebranding of roles through designations such as “manager”, “executive” or “supervisor”.

Applying these principles to the facts, the Court found that the appellant had no real supervisory authority, exercised no independent control over staff, and operated strictly under the instructions of his superiors. The designation conferred upon him was described as nothing more than an “eyewash”, insufficient to dislodge the substantive reality of his employment. On this basis, the Court conclusively held that he qualified as a “workman” under Section 2(s) of the Industrial Disputes Act.

The Supreme Court accordingly restored the Labour Court’s award, including reinstatement and back wages, and held that the High Court had committed a manifest error in interfering with well-reasoned findings of fact.

The ruling serves as a powerful reminder that substance prevails over form in labour law. It reinforces judicial consistency around the dominant nature test, protects employees from being arbitrarily excluded from statutory safeguards, and sends a clear message to employers: designations cannot be used as shields against compliance with labour legislation.