Civil Courts Have Jurisdiction Over Minimum Wages Act Disputes

The Pabbojan Tea Co. Ltd., etc. Versus The Deputy Commissioner, Lakhimpur, etc.

The Pabbojan Tea Co. Ltd., etc. Versus The Deputy Commissioner, Lakhimpur, etc. - 1968 AIR 271 (SC) Issues Involved:
1. Jurisdiction of civil courts to entertain suits under the Minimum Wages Act, 1948.
2. Applicability of the Minimum Wages Act to sub-normal workers (Letter a Challans).
3. Validity of orders issued by the Deputy Commissioner under the Minimum Wages Act.

Detailed Analysis:

1. Jurisdiction of Civil Courts to Entertain Suits under the Minimum Wages Act, 1948:
The primary issue was whether the civil courts had jurisdiction to entertain suits challenging the decisions made under the Minimum Wages Act, 1948. The court examined the provisions of the Act, particularly Section 20, which empowers an authority to hear and decide claims of non-payment of minimum wages. The court noted that the Act did not provide for an appeal or revision against the authority's decisions, and the penalties imposed by the authority could be substantial. The court emphasized that the exclusion of civil court jurisdiction must be explicitly expressed or clearly implied by the statute. It concluded that Section 20(6) of the Act did not exclude the jurisdiction of civil courts to entertain suits challenging the applicability of the Act to certain classes of workers, as the authority's decisions were not intended to be final in such matters. Therefore, the civil court had jurisdiction to entertain the suits.

2. Applicability of the Minimum Wages Act to Sub-Normal Workers (Letter a Challans):
The court examined whether sub-normal workers, referred to as Letter a Challans, were entitled to full minimum wages without performing a normal day's task or working the prescribed number of hours. The notification dated March 11, 1952, fixed minimum wages for "ordinary unskilled labour," which the court interpreted as laborers working in the ordinary way for the prescribed hours. The evidence showed that Letter a Challans were unable to work for the full nine hours due to old age, infirmity, or physical defects. The court held that these sub-normal workers did not fall within the category of "ordinary unskilled labour" and were therefore not entitled to full minimum wages. The court emphasized that the proviso to Section 15 of the Act applied, which states that an employee is not entitled to full wages if their failure to work is due to their unwillingness and not the employer's omission to provide work.

3. Validity of Orders Issued by the Deputy Commissioner under the Minimum Wages Act:
The court scrutinized the orders issued by the Deputy Commissioner on June 2, 1954, which directed the payment of the difference between the full minimum wages and the amounts actually paid to sub-normal workers, along with compensation. The court found that the Deputy Commissioner had not conducted a proper inquiry or recorded evidence before issuing the orders. The informal meeting at the Doom-Dooma Club was deemed insufficient to constitute a proper hearing. The court declared that the orders were not binding on the plaintiffs and issued a perpetual injunction restraining the enforcement of the orders. The court concluded that the sub-normal workers were not entitled to full minimum wages without performing the prescribed tasks or working the full hours, and the Deputy Commissioner's orders were invalid.

Conclusion:
The Supreme Court held that the civil courts had jurisdiction to entertain the suits challenging the decisions made under the Minimum Wages Act. It was determined that sub-normal workers (Letter a Challans) were not entitled to full minimum wages without performing a normal day's task or working the prescribed hours. The orders issued by the Deputy Commissioner were declared invalid, and a perpetual injunction was issued against their enforcement. The appeals were allowed, and the decrees of the Subordinate Judge and the High Court of Assam were set aside.