Workman status under industrial law turns on real duties, and a development officer without managerial powers qualifies as a workman.

Section 2(s) of the Industrial Disputes Act must be construed by looking to the real and predominant nature of the employee's duties, not by a narrow reading of the categories of manual, supervisory, technical or clerical work. A Development Officer of the Life Insurance Corporation, who was a whole-time employee without power to bind the corporation, appoint or discipline agents, or exercise administrative control, and whose functions were limited to business development, recruitment, training and assistance to agents, was not performing managerial or administrative work. He was therefore a workman within Section 2(s), and the maintainability objection failed.

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Issues: Whether a Development Officer of the Life Insurance Corporation was a "workman" under Section 2(s) of the Industrial Disputes Act, 1947.

Analysis: The definition of "workman" in Section 2(s) was held to be of wide amplitude and not to be narrowed by a restrictive reading of the words describing manual, supervisory, technical or clerical work. The decisive test was the nature of the duties actually performed. On the appointment terms and service conditions, the Development Officer was a whole-time employee assigned a defined area, without power to bind the Corporation, without authority to appoint or discipline agents, and without administrative control over them. His functions were confined to organising and developing business, recruiting and training agents, and assisting them, which did not amount to managerial or administrative work.

Conclusion: The Development Officer was a workman within the meaning of Section 2(s) of the Industrial Disputes Act, 1947, and the preliminary objection to maintainability failed.

Ratio Decidendi: In determining workman status under Section 2(s), the real and predominant nature of the employee's duties governs, and an employee who lacks managerial or administrative powers does not cease to be a workman merely because he is engaged in business development or supervision of agents.

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