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Checking relevance for V. Veeramani VS Management Of Madurai District Co-operative Supply And Marketing Society LTD. ...

V. Veeramani VS Management Of Madurai District Co-operative Supply And Marketing Society LTD. - 1994 0 Supreme(SC) 861 : The legal documents explicitly state that an industrial dispute does not abate or come to an end merely because the workman who was a party to the dispute has died pending adjudication. The court held that the heirs and legal representatives of the deceased workman are entitled to continue the proceedings. This directly contradicts the notion that inquiry proceedings cannot be challenged after the death of the workman. The judgment in Rameshwar Manjhi v. Sangramgarh Colliery confirms that the Tribunal does not become functus officio and the reference does not abate on the death of the workman, even in individual disputes under Section 2-A of the Industrial Disputes Act. Therefore, the death of the workman does not bar the continuation of inquiry proceedings by legal representatives.Checking relevance for Rameshwar Manjhi (Deceased) Through His Son Lakhiram Manjhi VS Management Of Sangramgarh Colliery...

Rameshwar Manjhi (Deceased) Through His Son Lakhiram Manjhi VS Management Of Sangramgarh Colliery - 1993 0 Supreme(SC) 1071 : The legal documents establish that inquiry proceedings can indeed be continued after the death of a workman. The court held that on the death of a workman during the pendency of an industrial dispute under Section 2A of the Industrial Disputes Act, 1947, the reference does not abate or become functus officio. Instead, the heirs and legal representatives of the deceased workman are entitled to agitate questions regarding whether the termination was just, legal, and proper, and if wrongful, to claim compensation for the period from a fixed date until the date of reinstatement (or until the date of death if reinstatement is not possible). This directly contradicts the notion that proceedings cannot be challenged after the workman''''s death.Checking relevance for Mamta Devi VS Reliance General Insurance Company Limited...

Checking relevance for Rashida Haroon Kupurade VS Div. Manager, Oriental Ins. Co. Ltd. ...

Checking relevance for MANISH KUMAR VS UNION OF INDIA...

Checking relevance for Shiv Das (Deceased) represented by His LRs VS South Eastern Coalfield Ltd. through Sub Area Manager...

Checking relevance for Mahadev Krishna Tambe (deleted as dead) vs Union of India represented by General Manger...

Mahadev Krishna Tambe (deleted as dead) vs Union of India represented by General Manger - 2025 Supreme(Online)(Bom) 4226 : The death of a workman during the pendency of inquiry proceedings does not abate the right of the legal heirs or representatives to continue the proceedings and claim benefits, including monetary relief, as successors to the deceased. This is based on the principle that the applicability of the maxim ''''actio personalis moritur cum persona'''' depends on the relief claimed and the facts of each case. In particular, claims for back wages or other monetary benefits are not extinguished by the workman''''s death, and the legal representatives may continue the proceedings to secure such benefits.Checking relevance for Ranjeet Singh VS Union Of India...

Ranjeet Singh VS Union Of India - 2022 0 Supreme(Raj) 1711 : The legal documents establish that inquiry proceedings cannot be automatically abated upon the death of a workman. In the case of Shri Rameshwar Manjhi v. Management of Sangaramgarh (1994) 1 SCC 292, the Hon''''ble Supreme Court held that the applicability of the maxim ''''actio personalis moritur cum persona'''' depends on the ''''relief claimed'''' and the facts of each case. While relief such as reinstatement cannot be granted after death, other claims like back wages or monetary relief may still be pursued by legal representatives. The court emphasized that proceedings should continue at the instance of legal heirs/representatives to maintain industrial peace and ensure benefits are available to successors of the deceased workman. This principle is reinforced by Rule 26 of the Railway Claims Tribunal (Procedure) Rules, 1989, which allows substitution of legal representatives within 90 days of death, indicating that claims do not end with the death of the claimant.Checking relevance for REKHA TOMAR VS MADHYA PRADESH WAREHOUSING AND LOGISTICS CORPORATION, BHOPAL...

Checking relevance for Kanta VS Gas Authority of India Ltd. ...

Kanta VS Gas Authority of India Ltd. - 2024 0 Supreme(Guj) 2196 : The legal documents establish that inquiry proceedings can indeed be continued after the death of a workman. The court held that the rights of a workman survive even after their death, allowing legal heirs to continue the industrial dispute proceedings. The Labour Court erred in denying the application to join legal heirs based on jurisdictional grounds, as the Labour Court must decide on the merits of the case rather than rejecting applications solely on jurisdictional grounds. Therefore, the claim that inquiry proceedings cannot be challenged after the death of a workman is incorrect under the applicable legal framework.

• Inquiry proceedings cannot be challenged after the death of a workman, as the rights and benefits associated with the proceedings survive the workman's death and can be claimed by legal heirs. The legal principle emphasizes that the dispute does not die with the individual workman, and proceedings can continue or be initiated by heirs or legal representatives ["Central Bank Of India VS Presiding Officer, Central Govt. Industrial Tribunal - Punjab and Haryana"].

• The validity of inquiry proceedings is crucial; if the inquiry was conducted properly and the findings are upheld, they form the basis for subsequent orders such as dismissal or reinstatement. However, even if the inquiry is found to be just and legal, the challenge to the proceedings can still be made, and the findings are subject to judicial review, unless they are challenged through appeals or higher courts ["Panchmahal Steel Limited VS Ranjitsinh Udaysinh Parmar (Deceased) - Gujarat"], ["Bilcho Kujur, W/o Late Johnson Lakra VS Tata Iron & Steel Company Limited - Jharkhand"].

• In cases where the workman dies during pendency of proceedings, the dispute can be continued by heirs or legal representatives, and the benefits or dues accrue to them. The proceedings do not automatically terminate with the workman's death, and the rights to claim compensation or back wages remain vested in the heirs ["JAMNAGAR MUNICIPAL CORPORATION VS MAMAD HUSSAIN MURIMA - Gujarat"], ["Central Bank Of India VS Presiding Officer, Central Govt. Industrial Tribunal - Punjab and Haryana"].

• Challenges to inquiry proceedings or orders based on procedural irregularities, such as non-supply of reports or violations of natural justice, can be raised, but the proceedings themselves are generally not rendered invalid solely on such grounds unless prejudice is demonstrated ["Bilcho Kujur, W/o Late Johnson Lakra VS Tata Iron & Steel Company Limited - Jharkhand"], ["Kumaon Mandal Vikas Nigam VS Presiding Officer Industrial Tribunal - Uttarakhand"].

• The legal position is that inquiry proceedings and the resultant orders are binding and cannot be reopened or challenged in writ proceedings unless they are found to be vitiated by illegalities or violations of principles of natural justice. The findings of fact by tribunals or courts, once made, are final unless challenged through appeal ["S. Raja VS Hindustan Unilever Ltd. , Tea Factory Manager - Madras"].

Analysis and Conclusion:Inquiry proceedings in industrial disputes are binding and can be challenged during the lifetime of the workman. However, after the workman's death, the proceedings and associated rights do not lapse; they can be continued or claimed by heirs. The legal framework supports the continuation of disputes post-mortem, and the rights to compensation or benefits are inheritable. Therefore, inquiry proceedings cannot be deemed unchallengeable solely due to the workman's death, but the proceedings themselves are subject to legal scrutiny and must adhere to principles of natural justice. The key insight is that the dispute's legal and procedural validity remains intact post-mortem, and the rights of the workman's heirs are protected under the law ["Central Bank Of India VS Presiding Officer, Central Govt. Industrial Tribunal - Punjab and Haryana"].