Modern corporate structures increasingly rely on sophisticated job titles such as Executive, Lead, Associate Manager, and Front Office Manager. While these designations appear managerial, the actual nature of work performed by employees often remains operational, clerical, or technical.
For many employers, such titles have functioned as a strategic tool to argue that employees fall outside the protection of the Industrial Disputes Act, 1947, particularly the statutory definition of a “workman”. However, Indian courts have consistently resisted allowing nomenclature to determine statutory rights.
The recent Supreme Court decision in Srinibas Goradia v. Arvind Kumar Sahu reaffirms this principle with renewed clarity. The Court emphasized that the legal status of an employee cannot be determined merely by designation. Instead, courts must examine the real and dominant nature of duties performed.
In an era marked by hybrid roles, flattened hierarchies, and evolving workplace structures, the judgment provides important guidance for employers, HR professionals, and labour law practitioners.
Case Analysis: Srinibas Goradia v. Arvind Kumar Sahu (2025)
The dispute arose from the termination of an employee working at a hospitality establishment under the designation “Front Office Manager/Executive.” The employee’s services were terminated without compliance with the retrenchment procedures prescribed under Section 25F of the Industrial Disputes Act, 1947, which mandates notice and payment of compensation before termination of a workman.
The employee challenged the termination, contending that despite the managerial designation, the nature of duties performed was essentially operational and administrative. The employer argued that the designation “Manager” itself excluded the employee from the statutory definition of “workman”.
The Supreme Court rejected this argument. It held that reliance on nomenclature alone is legally unsustainable and that courts must instead undertake a factual inquiry into the actual functions performed by the employee. The judgment therefore overturned the High Court’s approach, which had placed undue emphasis on the employee’s designation.
The Court reiterated that the protective framework of labour legislation cannot be diluted through artificial designation structures.
The Dominant Nature of Duties Test: Beyond the Title
Indian labour jurisprudence has long relied on the Dominant Nature of Duties test to determine whether an employee falls within the definition of “workman”. This doctrine becomes particularly relevant where employees perform a mixture of operational, supervisory, and administrative tasks.
Under this test, courts examine the principal or predominant function performed by the employee. If the primary nature of work is manual, technical, operational, or clerical, the employee may still qualify as a workman even if certain supervisory responsibilities exist.
In the Goradia decision, the Supreme Court highlighted several indicators that help distinguish genuine managerial roles from operational positions.
A key factor is independent authority within the organization. Managerial employees typically possess powers such as hiring personnel, initiating disciplinary proceedings, or terminating employees. Where such authority is absent and the employee merely implements decisions taken by senior management, the claim of managerial status becomes questionable.
Another important consideration is the ability to bind the organization through decisions. Employees who negotiate contracts, make financial commitments, or otherwise act on behalf of the company in a legally binding capacity are more likely to be classified as managerial personnel.
Courts also evaluate the extent and purpose of supervisory functions. If supervision forms the central function of the role—such as directing teams, allocating work, and exercising operational control—the employee may fall outside the category of workman. Conversely, where supervisory activities are merely incidental to technical or clerical work, they do not alter the essential character of the role.
Finally, the Court considers whether the employee participates in managerial decision-making structures, including policy discussions, strategic meetings, or administrative planning. Absence of such participation often indicates that the employee occupies an operational rather than managerial position.
Distinguishing the 2025 Jurisprudence from Earlier Precedents
The reasoning in Goradia aligns with and reinforces principles articulated in earlier decisions, including Bharti Airtel Ltd. v. A.S. Raghavendra. These precedents collectively emphasize that the determination of workman status must be grounded in functional reality rather than formal designation.
What distinguishes the 2025 judgment is the Court’s explicit recognition of contemporary corporate practices where titles are frequently used to project managerial authority without granting corresponding powers. The Court observed that such practices may amount to an “eyewash”, particularly where employees continue to perform operational or clerical tasks despite being described as managers.
By using this language, the Court signalled a stronger judicial stance against attempts to bypass statutory protections through cosmetic reclassification of roles.
Implications for International Firms and Employers
For multinational companies and international employers operating in India, the Goradia judgment carries significant compliance implications.
Termination decisions involving employees with titles such as Assistant Manager, Junior Manager, or Executive must be evaluated carefully. If the dominant nature of the employee’s duties remains operational or technical, the employee may still fall within the protective scope of the Industrial Disputes Act, 1947. Failure to comply with retrenchment provisions may expose employers to litigation, reinstatement orders, and substantial back-wage liabilities.
The judgment also increases the importance of accurate job descriptions and internal role documentation. Courts are likely to examine whether the responsibilities described in employment contracts reflect the employee’s actual daily work. Discrepancies between designation and functional authority may undermine an employer’s legal position.
Human resource teams may therefore benefit from periodically auditing employee roles to determine whether managerial titles correspond to genuine managerial functions such as disciplinary authority, policy participation, or decision-making powers.
Hybrid Roles and the Modern Workplace
The significance of the Dominant Nature of Duties test becomes particularly evident in modern hybrid roles.
Consider, for example, a technology company where a “Team Lead” spends the majority of working hours writing code and contributing to product development, while occasionally reviewing colleagues’ work or coordinating small tasks. In such circumstances, the supervisory component remains incidental to the employee’s primary technical function.
Under the reasoning articulated in Goradia, the employee would likely still qualify as a workman because the dominant character of the role remains technical rather than managerial.
This example reflects the broader shift in contemporary workplaces where hierarchical authority is often limited, even though managerial titles remain prevalent.
Managerial Status vs Workman Status
| Feature | Managerial Status (Excluded) | Workman Status (Protected) |
| Title | Designation not decisive | Designation not decisive |
| Disciplinary authority | Independent power to discipline or terminate employees | No independent disciplinary authority |
| Nature of work | Strategic supervision, policy, administration | Manual, clerical, technical or operational tasks |
| Incidental functions | May occasionally perform operational work | May occasionally coordinate or supervise colleagues |
| Decision-making authority | Ability to bind the organization | Works under instructions of superiors |
The Supreme Court’s decision in Srinibas Goradia v. Arvind Kumar Sahu reinforces a long-standing yet increasingly relevant principle of Indian labour law: the legal status of an employee depends on the substance of the work performed rather than the title assigned by the employer.
As corporate structures continue to evolve and hybrid roles become more common, the Dominant Nature of Duties test will remain the central judicial tool for determining workman status under the Industrial Disputes Act, 1947.
For employers, the judgment serves as a reminder that careful alignment between designation, authority, and actual responsibilities is essential to ensure compliance with labour legislation and to avoid protracted employment disputes.