Labour Legislations Being Beneficial in Nature Require Liberal Interpretation: MP High Court

The Madhya Pradesh High Court at Indore has dismissed a writ petition filed by Medicaps Limited challenging an order of the Industrial Court which had condoned delay in workmen’s claims and remanded the matter to the Labour Court for fresh adjudication, holding that labour legislations being beneficial in nature require a liberal approach, especially on the question of limitation.

A Division Bench comprising Justice Vijay Kumar Shukla and Justice Alok Awasthi was hearing a petition under Article 226 of the Constitution assailing the Industrial Court’s order dated June 25, 2025.

"...we find that the Tribunal had taken into consideration that the case was filed by the workmen and they specifically pleaded that they were not literate and were not aware of the legal provisions. Apart from that, the period was covered by the COVID-19 period and, therefore, a lenient view has to be taken on the point of limitation. In the case of Inder Singh V/s State of Madhya Pradesh, 2025 SCC OnLine SC 600, the Hon'ble Supreme Court said that a lenient view should be taken on the point of limitation", the court observed.

The petitioner-employer contended that the claims raised by the workmen were barred by limitation under Section 62 of the Madhya Pradesh Industrial Relations Act, 1960.

The dispute traces back to the closure of the petitioner’s industrial plant on November 22, 2019. According to Medicaps Limited, the closure was carried out after following due process of law and all statutory dues payable to employees under the Industrial Disputes Act, 1947 were settled. Despite this, certain workmen had earlier challenged the closure by filing applications under the MPIR Act. Those applications were rejected by the Labour Court in June 2024, and the Industrial Court subsequently dismissed the appeal, upholding the legality of the closure.

Thereafter, a separate set of workmen approached the Labour Court claiming that their services stood terminated on 22.11.2019 and that the nationwide COVID-19 lockdown, imposed a few months later, prevented them from pursuing timely legal remedies. When their claim was rejected by the Labour Court on the ground of limitation, they approached the Industrial Court, which condoned the delay by relying on the Supreme Court’s directions extending limitation during the COVID-19 period and remanded the matter for adjudication on merits.

Appearing for the petitioner, Advocate Kirti Patwardhan argued that the Industrial Court had erred in condoning an inordinate delay of nearly four years. She submitted that even after excluding the COVID-19 period, there remained an unexplained delay of about fifteen months, which could not have been brushed aside. It was further contended that the issue of closure had already attained finality and permitting fresh proceedings would amount to reopening settled issues.

The High Court, however, declined to interfere. It noted that the Industrial Court had taken into account the workmen’s plea that they were illiterate and unaware of legal provisions, and that the delay overlapped substantially with the pandemic period. The Bench relied on the Supreme Court’s decision in Inder Singh v. State of Madhya Pradesh (2025 SCC OnLine SC 600), which emphasised that a lenient view should be adopted while dealing with limitation, particularly where substantive rights are involved.

The Court observed that labour laws are beneficial legislations and cautioned against adopting a hypertechnical approach that could defeat the rights of workmen at the threshold. It further clarified that the employer would not be prejudiced, as all contentions on merits remain open to be urged before the Labour Court.

Accordingly, the writ petition was dismissed with no order as to costs, affirming the Industrial Court’s decision to remand the matter for fresh consideration.

Case Title: Medicaps Limited Through Factory Manager v. Smt. Sanju and Others

Order Date: 30.01.2026

Bench: Justice Vijay Kumar Shukla and Justice Alok Awasthi