Natural justice requires impleading affected workers in ESI proceedings before any adverse determination is made.

Proceedings under the Employees State Insurance Act are quasi-judicial and can entail civil consequences for workmen, so the employer and the affected workers are the real parties in interest. Where an employer challenges liability under the Act, the concerned workers, or at least some of them in a representative capacity or through their trade union, must be impleaded and heard before the Employees State Insurance Court. An order passed without giving them an opportunity of hearing is contrary to natural justice. The impugned judgments were set aside and the matter was remanded because the workers or their union had not been impleaded.

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Issues: Whether workers who may be directly affected by proceedings under the Employees State Insurance Act, 1948 must be impleaded before the Employees State Insurance Court, and whether an order passed without hearing them violates the principles of natural justice.

Analysis: Proceedings under the Act are quasi-judicial and may result in civil consequences for the workmen. The Act is a labour welfare legislation intended for the benefit of the workers, and the real parties in interest are the employer and the workers. Where an employer challenges liability under the Act, the concerned workers, or at least some of them in a representative capacity or their trade union, must be made parties so that any adverse determination is made after hearing those who are likely to be affected. A decision rendered without impleading or hearing the workmen is contrary to natural justice.

Conclusion: The impugned judgments were set aside and the matter was remanded because the proceedings before the Employees State Insurance Court were conducted without impleading the concerned workers or their union, in violation of natural justice.

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