Authority: Supreme Court of India, Civil Appellate Jurisdiction
Order Date: 16 September 2026
Case Overview
- Parties: The President, Canara Bank Staff Union (appellant) vs. The General Manager, Canara Bank (respondent).
- Origin: Appeals arise from a common judgment of the Bombay High Court dated 1 April 2025 in Writ Petition No.1318/2025, which itself reviewed an order of the Regional Labour Commissioner (Central), Pune dated 18 September 2024.
- Background: The Union, on behalf of 53 workmen, filed a claim under Section 20 of the Minimum Wages Act, 1948 alleging payment of wages below the statutory minimum for the period 01‑04‑2019 to 31‑08‑2022. The claim was filed more than six months after the wages became payable; the Commissioner exercised the power under the second proviso to Section 20 to condone the delay and allowed the claim for 36 workers.
- Commissioner’s Order (18 Sept 2024): Directed Canara Bank to pay Rs 42,38,265 as wage arrears plus 10 % compensation of Rs 4,23,828, totaling Rs 46,62,093, and to deposit the amount directly into the workers’ bank accounts or via demand draft in favour of the Assistant Labour Commissioner, Mumbai.
- High Court’s Modification: While upholding the finding that 36 workers were entitled to arrears, the High Court limited the payable period to six months prior to the claim filing date (i.e., from 1 May 2022), relying on Union of India v. Tarsem Singh (2008) and State of Madhya Pradesh v. Yogendra Shrivastava (2010).
- Bank’s Contentions: Challenged the High Court’s limitation, argued no justification for condoning delay, and asserted a settlement existed between the Union and the Bank (the latter claim was found unsupported).
- Supreme Court’s Reasoning:
- Condonation of delay: The Court held the Commissioner correctly exercised discretion to condone delay, considering the workers’ poor and illiterate background.
- Limitation on relief: The Court distinguished the High Court’s reliance on Tarsem Singh and Shrivastava, noting those cases dealt with situations lacking a statutory power to condone delay. Here, the second proviso to Section 20 expressly empowers the Authority to condone delay, and once condoned, there is no legal restriction on the period for which relief may be granted.
- Settlement plea: No evidence of any settlement was found on record; the Court therefore did not consider it.
- Cited precedents: Sitaram Ramcharan v. M.N. Nagarshana (rejection of condonation) was distinguished because the present case involved a valid condonation.
Final Outcome
- The appeal filed by the Canara Bank Staff Union (SLP (C) No. 24331/2025) is allowed.
- The High Court’s modification limiting the arrears to six months is set aside; the original Commissioner’s order is restored.
- Canara Bank must calculate the wage difference for the 36 workers from 1 May 2022 onward, include the 10 % compensation on the modified sum, and pay the total within four weeks, either directly into the workers’ accounts or by demand draft to the Assistant Labour Commissioner, Mumbai.
- The appeal filed by Canara Bank (SLP (C) No. 10128/2026) is dismissed.
- Any pending applications, if any, stand disposed of.
Topics: Minimum Wages, Labour Law, Judicial Relief