Introduction:

In Chandrashekhar v. The Divisional Controller, WRIT PETITION NO. 106142 OF 2024, the Karnataka High Court set aside the suspension of a constable employed with the Kalyan Karnataka Road Transport Corporation (KKRTC), who was penalized for being caught sleeping on duty. Justice M. Nagaprasanna, while delivering the judgment, underscored the significance of adequate sleep and work-life balance, stating that depriving an individual of sleep leads to fatigue and unintentional sleep episodes. The petitioner, Chandrashekhar, had been assigned consecutive double shifts for 60 days without a break, leading to exhaustion. His brief nap was recorded and circulated on social media, prompting disciplinary action. The Corporation argued that his conduct brought disrepute, justifying his suspension. However, the court, referencing Article 24 of the Universal Declaration of Human Rights and international labour standards, ruled that excessive work hours violate fundamental labour rights. The judgment acknowledged that employees working long shifts must have adequate rest, and holding the petitioner accountable for sleeping under such circumstances was unjust. The court ruled that his suspension lacked bona fides and was unsustainable, thereby reinstating him.

Arguments of Both Sides:

The petitioner, Chandrashekhar, represented by Advocates Ravi Hegde and Vinay Kumar Bhat, argued that his suspension was unjustified as he had been overburdened with continuous shifts beyond permissible working hours. He had been assigned double shifts—16 hours a day—for 60 consecutive days, leaving him physically exhausted. He stated that he had taken medicine as per his doctor’s advice and had merely taken a brief 10-minute power nap. He contended that the excessive workload imposed by the corporation had directly contributed to his fatigue. Furthermore, the Vigilance Department report acknowledged the insufficient manpower at the depot and recommended appointing two additional constables to address the workload issue. The petitioner emphasized that his action was not an act of negligence but a consequence of his strenuous work schedule.

On the other hand, the respondent, represented by Advocate Prashant S. Hosamani, maintained that the petitioner was caught sleeping while on duty, which was video-recorded and circulated on social media. This, they argued, tarnished the reputation of the Corporation, warranting disciplinary action. The Corporation insisted that employees must remain vigilant at all times during their duty hours, and sleeping while on duty was a serious offence. They justified the suspension by citing the potential risks associated with a lapse in duty.

Court’s Judgment:

The Karnataka High Court meticulously examined the circumstances surrounding the petitioner’s suspension. The bench noted that the duty schedule for a KST constable was ordinarily eight hours per day. However, in this case, due to a shortage of staff, the petitioner was compelled to work consecutive shifts for 16 hours a day without respite for two months. The court observed that such prolonged working hours contravened international labour norms, particularly the covenants of the International Labour Organization (ILO), which limit work hours to a maximum of 48 hours per week and eight hours per day, except in exceptional circumstances.

Justice M. Nagaprasanna emphasized that sleep is an essential human necessity, and depriving employees of rest results in unintended lapses in alertness. The court held that if the petitioner had fallen asleep during a regular eight-hour shift, it could be considered misconduct. However, under the prevailing circumstances, where he was subjected to continuous overwork, the fault lay with the Corporation rather than the petitioner. The court also referenced Article 24 of the Universal Declaration of Human Rights, which recognizes every individual’s right to rest, leisure, and reasonable working hours.

The judgment further highlighted that labour laws aim to protect workers from exploitation and ensure a fair work-life balance. It stated that the petitioner’s case was emblematic of a larger issue where employees across various sectors are overburdened with excessive workloads without adequate rest. The court criticized the Corporation’s approach, remarking that punishing an employee for circumstances created by the employer itself was unjust. It ruled that the order of suspension suffered from a lack of bona fides and was, therefore, unsustainable.

Granting relief to the petitioner, the court set aside the suspension order and directed the Corporation to reinstate him immediately. The ruling reaffirmed that employees should not be penalized for circumstances beyond their control, especially when arising from excessive workloads. The court also urged the Corporation to address staffing shortages to prevent similar incidents in the future.