Dominant clerical duties control workman status despite incidental supervisory tasks under industrial law.

An employee remains a workman under Section 2(s) of the Industrial Disputes Act, 1947 where the primary and dominant nature of the duties is clerical. Incidental supervisory, administrative, or ancillary tasks do not alter the character of employment if they are stray or minor and do not amount to managerial or supervisory work. On the evidence, the employee's substantial functions were clerical, and the contrary Labour Court inference was held impermissible and perverse. The employee was therefore treated as a workman, and the finding to the contrary could not stand.

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Issues: Whether the appellant was a "workman" within the meaning of Section 2(s) of the Industrial Disputes Act, 1947, notwithstanding some supervisory, administrative, or ancillary duties.

Analysis: The controlling test is the primary, basic, or dominant nature of the duties for which the employee is engaged. Where the main duties are clerical, the character of employment is not altered by stray or incidental supervisory tasks or by labels such as assistant, group leader, or covenanted contractual staff cadre. On the evidence, the appellant's substantial work remained clerical: the additional functions relied on by the employer were either mechanical clerical tasks, minor coordination within a small group, or administrative-looking acts that did not amount to managerial or supervisory employment. The Labour Court's contrary inference was held to be impermissible and perverse.

Conclusion: The appellant was a workman within Section 2(s) and the finding to the contrary could not stand.

Ratio Decidendi: An employee whose primary and dominant duties are clerical does not cease to be a workman merely because he performs incidental supervisory or administrative tasks.

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