Question

A teacher is not a workman falling under the category of Workman under Industrial. Disputes Act, 1947.This was upheld in which case

• A. Miss A. Sundarambal v. Government Of Goa, Daman And Diu & others
• B. Ahmedabad Pvt. Primary Teachers' Association v. Administrative Officer And Ors
• C. University of Delhi v. Ramnath
• D. Secretary, Madras Gymkhana Club Employees Union v. Management Of The Gymkhana

Hint:

Remember the \textit{Sundarambal} case as the final word on the status of teachers under the ID Act. The Supreme Court's reasoning was that the work of a teacher is primarily intellectual and creative, falling outside the specific categories mentioned in the definition of 'workman'.

Answer 1

The Correct Option is A

Step 1: Understanding the Concept:
The definition of 'workman' under Section 2(s) of the Industrial Disputes Act, 1947, has been a subject of extensive judicial interpretation. The definition includes persons doing manual, unskilled, skilled, technical, operational, clerical, or supervisory work. The question asks for the landmark case where the Supreme Court decided whether a 'teacher' fits into this definition.
Step 2: Detailed Explanation:
\begin{itemize} \item In the case of University of Delhi v. Ramnath (1963), the Supreme Court had held that the work of imparting education is not an 'industry', and therefore teachers are not 'workmen'. \item This position was reaffirmed and definitively settled in the case of Miss A. Sundarambal v. Government of Goa, Daman & Diu & others (1988). The Supreme Court, after analyzing the nature of a teacher's work, held that teachers are not 'workmen' within the meaning of Section 2(s) of the Industrial Disputes Act. \item The Court reasoned that the main work of a teacher is imparting education, which is a noble profession. A teacher's work is neither manual, clerical, nor technical in the sense that these terms are used in the Act. They are not engaged in an 'industry' but are in the field of education. This judgment remains the leading authority on the subject. \item The Ahmedabad Teachers' Association case also dealt with teachers but Sundarambal is the more cited and definitive Supreme Court judgment on this specific point. \end{itemize}
Step 3: Final Answer:
The principle that a teacher is not a workman under the Industrial Disputes Act was upheld in Miss A. Sundarambal v. Government Of Goa, Daman And Diu & others.