In Srinibas Goradia v. Arvind Kumar Sahu & Ors (SLP 3682/2025, decided on December 17, 2025), the Supreme Court has reiterated that the dominant nature of duties performed by an employee — and not the job designation or incidental tasks — is the decisive factor in determining whether a person qualifies as a “workman” under the Industrial Disputes Act, 1947.
A Bench comprising Justices Prashant Kumar Mishra and N.V. Anjaria held that the occasional performance of supervisory, clerical or manual duties by an employee is not determinative. What matters is the principal and substantive nature of work for which the employee is engaged.
The Court observed that in modern industrial organisations, employees often perform a combination of duties. However, the correct test is a realistic assessment of the primary nature of work actually performed. Indicators such as effective supervisory powers, independent exercise of authority, the power to issue commands and control over subordinate staff are crucial in identifying a supervisory or managerial role.
The Bench clarified that the mere presence of supervisory elements does not convert an employee into a supervisor. Even manual work may involve some degree of supervision, but that alone cannot exclude an employee from the definition of a “workman.” The “acid test,” the Court said, is the dominant nature of duties.
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The Court further ruled that nomenclature or designation is not a guiding factor. What is relevant is the prominent and dominant nature of the work assigned and actually performed. The Bench noted that managements often use high-sounding designations such as “manager,” “supervisor,” or “executive” to suit their interests.
Emphasising this, the Court held that an employee who substantially performs manual work without supervisory authority cannot be treated as a supervisor merely because of the title attached to his post. Such an employee would continue to fall within the definition of a “workman” under Section 2(s) of the Act.
Facts of the case
Srinibas Goradia was appointed as a cashier in M/s Sai International Hotels Pvt. Ltd., Rayagada. After 12–13 years of service, his salary was abruptly stopped and his services were terminated in 2018 with an offer of one month’s notice pay.
The Labour Court held that the dispute was an industrial dispute, that the hotel was an industry, and that Goradia was a workman under the Act. It also found that he had completed more than 240 days of continuous service and that his termination violated Section 25(F) of the Act. Accordingly, it ordered his reinstatement with back wages.
The High Court, however, set aside the award, holding that Goradia was appointed as a manager or front office supervisor.
What SC Held
Allowing Goradia’s appeal, the Supreme Court found that he was originally appointed as a cashier. Though the management described him as a front office manager and even issued him an identity card showing him as an executive, these labels did not reflect the true nature of his duties.
The Court observed that Goradia worked mainly as a receptionist, handled hotel boys, and performed manual and clerical tasks. He had no authority to sanction leave, did not attend managerial meetings, and exercised no independent supervisory or managerial powers. The designation given to him, the Bench said, was “merely an eyewash.”
Applying the dominant nature test, the Court held that Goradia’s principal duties clearly established him as a “workman” under Section 2(s) of the Industrial Disputes Act, 1947.
Finding that the High Court had committed a manifest error, the Supreme Court restored and upheld the Labour Court’s award and directed the employer to comply with the order within two weeks.
