Fixed-term termination as retrenchment requires compensation compliance, or the termination becomes invalid under labour law.

Termination of a workman on expiry of a fixed-term temporary appointment is treated as retrenchment where the Industrial Disputes Act's express exclusions do not apply. The text states that retrenchment has wide amplitude and that the substance of the employment arrangement, not the form of the appointment order, is decisive. It further states that compliance with the retrenchment compensation requirement is a condition precedent under Section 25F, so non-payment renders the termination invalid and inoperative. On the facts described, the termination was therefore treated as unlawful and reinstatement followed.

---

---

Issues: Whether termination of a workman under a temporary appointment for a fixed term, by expiry of the stipulated period, amounts to retrenchment within the meaning of Section 2(oo) of the Industrial Disputes Act, 1947, so as to attract Section 25F and invalidate the termination on non-payment of retrenchment compensation.

Analysis: The expression "retrenchment" in Section 2(oo) was held to be of wide amplitude, covering termination of service "for any reason whatsoever" except the express exclusions. The Court applied a purposive construction to the welfare statute and held that the substance of the transaction, not the form of the appointment order, is decisive. A termination occurring on expiry of the fixed term, even if described as automatic cessation, is still termination by the employer within the statutory definition. Since Section 25F makes payment of retrenchment compensation a condition precedent to retrenchment of a workman who has completed the requisite continuous service, non-compliance renders the termination invalid and inoperative.

Conclusion: Termination on expiry of the temporary fixed-term appointment amounted to retrenchment, compliance with Section 25F was mandatory, and the impugned termination was invalid. Relief of reinstatement followed on the facts of the case.

Ratio Decidendi: Under the Industrial Disputes Act, 1947, retrenchment includes termination of service for any reason whatsoever other than the statutory exclusions, including cessation on expiry of a fixed term, and non-compliance with the compensation requirement in Section 25F renders such termination invalid.

---