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As per case facts, the appellant, initially a Stenographer-cum-Accountant, was promoted to Assistant and designated 'Group Leader' before his services were terminated. The employer contested the dispute, claiming the appellant
...was not a 'workman' under the Industrial Disputes Act, arguing his role was supervisory/managerial. The Labour Court initially sided with the employer, dismissing the reference, a decision upheld by the High Court in a writ petition. The appellant then appealed to the Supreme Court. The question arose whether an employee with multifarious duties, especially those designated as 'Group Leader' with some supervisory tasks, still qualifies as a 'workman' under the Act, or if their primary duties must be assessed to determine their true status. Finally, the Supreme Court ruled that the appellant was indeed a 'workman'. The court emphasized that the primary, basic, or dominant nature of duties should determine an employee's status, and a few incidental supervisory tasks do not change the core character of an otherwise clerical role. The Labour Court's initial finding was deemed perverse for misinterpreting the evidence and drawing impermissible inferences, especially regarding the 'Group Leader' designation not inherently making the role managerial.
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