Abolition of all posts is not a reduction in staff under industrial dispute settlement law, so Section 31 procedure does not apply.

Abolition of all posts does not amount to a mere reduction in the number of persons employed within the meaning of Section 31 of the C.P. and Berar Industrial Disputes Settlement Act. Section 31 applies where an employer proposes a change in standing orders or in an industrial matter covered by Schedule II, including a permanent or semi-permanent reduction in staff. The Court reasoned that reduction presupposes that some posts or employees remain after the change; the wholesale abolition of an establishment or all its posts falls outside that ordinary meaning. Accordingly, Section 31 was not attracted and the procedural requirements under that provision did not apply.

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Issues: Whether the abolition of all posts and the consequent termination of employees amounted to a change covered by Section 31 of the C.P. and Berar Industrial Disputes Settlement Act.

Analysis: Section 31 applies where an employer intends to effect a change in standing orders or in respect of an industrial matter specified in Schedule II. Item 1 of Schedule II refers to reduction, intended to be of a permanent or semi-permanent character, in the number of persons employed or to be employed. The Court held that abolition of all posts is not a mere reduction in the number of employees, because reduction presupposes that something remains after the reduction. Abolition of the whole establishment or all its posts does not fall within the ordinary meaning of reduction under the Schedule.

Conclusion: Section 31 was not attracted, and the Government was not bound to follow the procedure prescribed by that provision.

Ratio Decidendi: Abolition of all posts does not amount to a reduction in the number of persons employed within the meaning of the industrial dispute settlement provision governing notice and negotiation for changes in service conditions.

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