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of <h1>Employee termination dispute seeking interim reinstatement after discharge implemented; injunction refused as damages adequate, not exceptional.</h1> Interim relief in a service-termination dispute was sought to effectively restore the claimant to employment after the discharge order had already been ... - 1. ISSUES PRESENTED AND CONSIDERED (i) Whether interim injunction directing/ensuring reinstatement in service could be granted when the termination/discharge order had already been implemented, applying the settled tests of prima facie case, balance of convenience, and irreparable injury. (ii) Whether, on the facts, the availability of compensation by damages defeated the requirement of irreparable injury and the balance of convenience for grant of interim relief in a service-termination dispute. 2. ISSUE-WISE DETAILED ANALYSIS Issue (i): Grant of interim injunction amounting to reinstatement after implementation of termination Legal framework (as discussed by the Court): The Court reiterated that grant of interim injunction depends on three essential ingredients-(a) prima facie case, (b) balance of convenience, and (c) irreparable loss/injury not compensable in money. The Court treated these as mandatory cumulative requirements for interim relief. Interpretation and reasoning: The Court noted that the discharge/termination had already been implemented and communicated. In that situation, an interim order staying the discharge or restoring the appellant to office would, in substance, grant the final relief claimed in the suit at an initial stage before issues were framed and evidence recorded. The Court accepted the approach that courts should be slow to grant interim relief that effectively decides the substantive dispute pending trial. Conclusion: Because the termination stood implemented, an interim injunction resulting in reinstatement would practically amount to decreeing the suit at the interlocutory stage; therefore, interim injunction was not warranted. Issue (ii): Whether damages being an adequate remedy negated irreparable injury and balance of convenience Legal framework (as discussed by the Court): The Court applied the principle that no temporary injunction should be issued unless all three elements (prima facie case, balance of convenience, irreparable injury) are satisfied, and that where the injury is compensable in terms of money, interim relief is ordinarily not called for in cases of dismissal/removal/termination, except in very exceptional cases. Interpretation and reasoning: The Court held that even assuming the appellant asserted illegality in the board resolution leading to discharge, the interim stage required a strict assessment of balance of convenience and irreparable injury. The Court found that any loss arising from the alleged wrongful discharge could be compensated by damages if the appellant ultimately succeeded. It further held that the matter was not shown to be a 'very exceptional case' justifying departure from the ordinary rule against reinstatement-type interim orders in termination matters. Conclusion: Since monetary compensation would be an adequate remedy on success, the appellant failed on irreparable injury and balance of convenience; consequently, interim injunction for reinstatement was rightly refused and the dismissal of the appeal was affirmed.
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