Judicial service coverage of Labour Court presiding officers requires recruitment under the constitutional scheme for subordinate courts.

Presiding officers of Labour Courts were treated as part of the judicial service of the State because Labour Courts discharge exclusively judicial functions within an independent civil judicial hierarchy. The constitutional scheme in Part VI was applied to read "judicial service" in Article 236(b) broadly, so that specialised judicial hierarchies such as Labour Courts and Industrial Courts fall within it. As a result, recruitment to presiding offices of Labour Courts had to comply with Article 234, read with the constitutional control over subordinate courts under Article 235.

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Issues: Whether presiding officers of Labour Courts under the relevant labour statutes constitute part of the judicial service of the State, and whether their recruitment must conform to the constitutional scheme under Articles 234 and 235 of the Constitution of India.

Analysis: The Labour Court performs judicial functions and decides disputes of a civil nature. Applying the constitutional scheme in Part VI, the expression "judicial service" in Article 236(b) was construed as a service consisting exclusively of persons intended to hold civil judicial posts, with a hierarchy of courts headed by the District Judge. The extensive definition of "District Judge" was read broadly enough to include specialised civil judicial hierarchies such as Labour Courts and Industrial Courts. The earlier decisions on judicial service and judicial office were treated as supporting the principle that persons who discharge only judicial functions and form an exclusive judicial hierarchy fall within the constitutional concept of judicial service. On that basis, the appointments to presiding offices of Labour Courts could not be made outside the constitutional requirements governing recruitment to the judicial service.

Conclusion: The presiding officers of Labour Courts were held to belong to the judicial service, and their recruitment was required to be made in accordance with Article 234 read with the constitutional control of subordinate courts under Article 235.

Final Conclusion: The challenge to the impugned appointments failed, and the constitutional validity of recruiting Labour Court judges within the judicial service framework was upheld.

Ratio Decidendi: A specialised court that exercises exclusive judicial functions within an independent judicial hierarchy forms part of the judicial service of the State for the purposes of Articles 234 to 236 of the Constitution of India.

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