The Karnataka High Court set aside the suspension of a constable from the Kalyan Karnataka Road Transport Corporation (KKRTC), who was penalized for sleeping on duty after working double shifts regularly. Justice M. Nagaprasanna, while delivering the judgment, underscored the essential need for sleep and work-life balance in a demanding work environment.
Case Background
The petitioner, Chandrashekhar, a constable at KKRTC’s Kukanoor Depot, was found asleep on duty on April 23, 2024. A vigilance report captured this incident on video, which was later circulated on social media. As a result, he was placed under suspension by the corporation, citing misconduct that tarnished the organization's reputation.
However, Chandrashekhar argued that he had been assigned continuous second and third shifts without adequate rest. He also stated that he had taken medication as prescribed by a doctor and had merely taken a short power nap due to exhaustion. The Vigilance Department itself reported that the depot had only three constables handling an overwhelming workload, recommending the appointment of additional staff.
Court’s Observations
Justice M. Nagaprasanna emphasized the fundamental necessity of sleep for human functioning:
"If a person is forced to overwork beyond their capacity, the body compels them to sleep. Sleep and work-life balance are crucial today."
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The court acknowledged that employees in any organization, especially those working in shifts, require a balance between work and personal life. The ruling cited Article 24 of the Universal Declaration of Human Rights, which guarantees everyone the right to rest and leisure, including limitations on working hours and periodic paid holidays.
Key Findings
The bench found that:
- The duty hours for a KKRTC constable are typically eight hours per day.
- Due to a shortage of personnel, Chandrashekhar was forced to work double shifts (16 hours daily) continuously for 60 days.
- The International Labour Organization (ILO) mandates a maximum of 48 work hours per week and eight hours per day, with only exceptional circumstances allowing deviations.
- Legal precedents, including rulings by the Calcutta and Uttarakhand High Courts, uphold the right to sufficient rest and humane working conditions.
Judicial Precedents Supporting the Ruling
The court referred to several landmark judgments affirming the importance of rest and work-life balance:
"Under our Constitution, people have a right to sleep and leisure. Sleep deprivation can lead to mental stress, decreased efficiency, and adverse health effects." – Calcutta High Court in Burrabazar Fire Works Dealers Assn. v. Commissioner of Police, 1997.
Additionally, the Uttarakhand High Court in Arun Kumar Bhadoria v. State noted:
"Legal provisions regulate work hours globally, ensuring just and humane working conditions. International standards aim to maintain workers’ health and a work-life balance."
Final Verdict
The Karnataka High Court ruled in favor of the petitioner, stating:
"If the petitioner had slept while working a single shift, it would constitute misconduct. However, making him work 16-hour shifts for 60 consecutive days and then penalizing him for exhaustion is unfair."
The suspension order dated July 1, 2024, was quashed, and Chandrashekhar was reinstated with full benefits, including salary and continuity of service. The court criticized the corporation’s failure to address staff shortages, which forced employees into excessive work hours without proper rest.
Appearance: Advocates Ravi Hegde, Vinay Kumar Bhat for Petitioner.
Advocate Prashant S Hosamani for Respondent
Case Title: Chandrashekhar AND The Divisional Controller.
Case No: WRIT PETITION NO. 106142 OF 2024
