Workman or Manager? Employee? Worker? - Clarifying the Position in the Labour Law

By Eashaan Agrawal

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Labour laws in India have been enacted with the aim of providing some rights and benefits to the people engaged employed and in the case of violation of those legal rights, an appropriate remedy. In the post-pandemic world, there has been a relaxation of the labour laws in some states to spur economic growth[1]. It is in this situation it often becomes important to know who are the beneficiaries of such labour laws.

In India, we have many laws to protect the rights of those employed. Such legislations include the Minimum Wages Act, 1948, the Trade Unions Act, 1926, the Industrial Dispute Act, 1947, the Factories Act, 1948 among many other laws. These legislations often have different objectives sought to be achieved. To ensure this, these legislations define the beneficiaries, to whom the protection of the concerned legislation will be granted and thus create a distinction within those employed in different workplaces. Since ‘Labour’ is a subject under the concurrent list, both the state governments and the central government have the power to make laws. Thus, apart from the above-mentioned central legislation, states also have enacted their respective labour laws, including the Shops and Establishment Acts of the relevant states.

 

Categorisation of Employees

According to the various labour laws, there are different categories of people who are the employees, the workmen, the workers, and the managers.


The term ‘employee’ has been defined in the Employees’ Provident Funds And Miscellaneous Provisions Act 1952 under section 2(f) as any person who is employed

1)      For wages,

2)     In any kind of work, manual or otherwise, in or in connection with the work of an establishment, and

3)     Gets his wages directly or indirectly from the employer.

This is the widest definition under the labour law and thus includes other categories of people including the workers, the workmen, and the managers. However, for the sake of understanding, employees in this article will have the common meaning of a person being employed by someone.


The term ‘worker’ has been defined in the Factories Act 1948 under Section 2(l)[2]. According to it, a person has to meet the following conditions to be called a worker.

1)    Employed, with or without knowledge of the principal employer,

2)    Either directly or through a contractor or agency,

3)    For remuneration or not,

4)    Should be employed in either manufacturing process, or in cleaning any part of the machinery or premises used for a manufacturing process, or in any other kind of work incidental to, or connected with, the manufacturing process, or the subject of the manufacturing process, and

5)    Should not be a part of the armed forces of the Union.


The term ‘workman’ has been defined in the Industrial Disputes Act 1947 under section 2(s). According to it, a person will be qualified to be a workman if he meets the following criteria:

1)     The person should be employed in any industry, he might be an apprentice;

2)     The person should be engaged in any unskilled, skilled, technical, operational, clerical or supervisory work;

3)     Employment should be for the purpose of hire or reward;

4)     The terms of employment can express or implied;

5)     Further, to claim the benefit of this Act the person should be in a dispute;

6)     Therfore, this also includes a person who has been dismissed, discharged, or retrenched in connection with a dispute or as a consequence of which a dispute has arisen.

The Act specifically excludes people from the armed forces, the police service, those employed in a managerial or administrative capacity and those who are in supervisory capacity and drawing wages exceeding Rs. 10,000.


The term ‘manager’ therefore refers to those people employed in an organisation who are in a supervisory capacity or have some authority over the workers, workmen, employees, or anyone else working in the organisation (that is, other managers). The term is also sometimes used to refer to those people working in an organisation who do not strictly fall under any of the other categories.


As we can see, the Acts seem to distinguish between a worker, a workman, and a manger. In fact, the protection in most cases is granted only to the former two and not those engaged in managerial work. Further, we can see that while there has been some attempt at creating a distinction there still remains uncertainty on who is a manager and there is a need for some concrete definition of the same.

Companies often misuse this ambiguity to categorise workmen bringing disputes, particularly related to dismissal, as managers by arguing that they had some kind of supervisory authority or by showing that they earned more than Rs. 10,000 (while this should ideally be based on only the basic wage, some companies include all other elements of the total cost to the company to reflect a higher earning). While the labour courts do conduct investigations to prevent such misuse, the law should certainly be amended to bring in statutory clarity. This will help avoid excessive litigation and also bring more clarity to the employees about their rights and entitlements.

 

Contractual Liability

The statutes override the contract entered into between the parties and thus, in case of restriction of the right of the employee, the employee can take legal actions. The contract can be written or oral; express or implied and thus cover a vast range of employer-employee relations. Also, in case the person is not covered by the statute, like in the case of a manager, the terms of the contract will be considered as the authority insofar as the rights of the employee is concerned.  

Further, since the employment contracts are subject to the statutes, the provisions beneficial to the employee are considered as implied in the contract. Such terms include payment of wages, statutory bonuses, gratuity payments and mandatory social security contributions.


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Eashaan is a 2nd year law student at National Law University Delhi. A voracious reader, he loves to travel to new places and experience the culture of different places. His interests include Constitutional Law, Contracts and Law of Crimes.

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