SINDH INDUSTRIAL RELATIONS ACT 2013
Inconsistencies, Anomalies & Omissions

By:
MAHMOOD ABDUL GHANI
Advocate Supreme Court of Pakistan

In March 2013 whilst the Sun was setting, our elected representatives moved a Bill in the Provincial Assembly of Sindh which reads as under:-

“After the Eighteenth Amendment in the Constitution of Islamic Republic of Pakistan, 1973, subject “Labour” has been devolved to the Provinces.  To regulate the formation of trade union, regulation and improvement of relation between the Employer and Workman, it is expedient to enact a Provincial Law in the subject matter.”

With such awakening, a Law was moved in the Provincial Assembly of Sindh and was enacted as such by the Assembly without any discussion and passed the same day.  Subsequently it even received accent of the Governor of the Province.  On 28th March, 2013, the date of Notification is 1st April, 2013 but published in the Sindh Government Gazette dated Monday March 11, 2013.  A dispassionate examination of this Act promulgated after the Eighteenth Amendment in the Constitution of Islamic Republic of Pakistan, 1973, and with the subject of Labour being devolved to the Provinces, our Provincial Assembly has thrown the baby with the bathwater from the tub proclaiming devolution of subject Labour to the Provinces.  Einstein definition of insanity: doing the same thing over and over again and expecting different results.  From stale porridge we have tried before, we are expecting something new.  There is no easy cure for such a malady. It is best to do things systematically, since we are only human, and disorder is our worst enemy.  The Law so promulgated consist of inconsistencies, anomalies and omissions which are discussed herein after.

In terms of Section 3 of the Act, in short SIRA 2013 it is mentioned that it will apply to all persons employed in any establishment or industry including fishing and agriculture.  Unfortunately, Livestock, Cattle, Sheep and Poultry Farming and Plantation stands omitted unconsciously as this Law was moved in haste.  Furthermore the Law provides a list of institutions and establishment not covered under the purview of the said Act. Earlier the Federal Government had promulgated Industrial Relations Act 2012 declaring that Pakistan has ratified ILO Convention No. 87 on Freedom of Association and Convention No. 98 on Right to organize and Collective Bargaining.  Article 17 of the Constitution of Islamic Republic of Pakistan, 1973 provides for Freedom of Association.  Every citizen shall have a right to form Association or Union subject to any reasonable restriction imposed by Law in the interest of sovereignty or integrity of Pakistan, public order or morality.  It is not known what sovereignty of Pakistan, public order or morality was involved whilst excluding large number of establishments from the ambit of the SIRA 2013.  To the extent of exclusion of Defence Service of Pakistan, Police or any service or Installations exclusively connected with Armed Forces of Pakistan, or those employed in the administration of the State, such exclusion may be justified, but excluding PIA, members of security staff in Group V, Pakistan Security Printing Corporation or Security Papers Limited, establishment for treatment or care of sick, infirm, destitute or mentally unfit persons, members of Watch and Ward, Security or Fire Service Staff of oil Refinery on an airport, members of a security or fire Service staff of an establishment engaged in the production, transmission or distribution of natural gas or liquefied petroleum gas, institution or establishment providing education or emergency services excluded from the ambit of law altogether, is contrary to Article 17 read with Article 25 of the Constitution as also the principle laid down by the Supreme Court of Pakistan  in case of Civil Aviation reported in 1997 PLC 653.  This exclusion is liable to be challenged, and in all probability struck down by the Superior Judiciary as violative of Constitution.  Partial exclusion of SIRA 2013 in PIA on the basis of grade is not correct.  If any, it should be on the basis of duties, responsibilities and power.

In Section 2 of the Act which defines certain terms used in the Act, the concept of Collective Bargaining Unit has been introduced.  Such a concept is understandable in legislation which are trans-provincial in nature, subject to Article 144 of the Constitution but its insertion in Section 2 of the said act will add to further chaos and confusion.  Section 2 (viii) has defined the term ‘employer’ as any person who employs workmen under a contract of employment and includes any person responsible to the management for supervision and control of the establishment.  It appears that Provincial Legislators have not even considered the definition of the term ‘employer’ as given in Section 2 (ix) of IRA 2012 promulgated by the Federal Government and published on 14-03-2012.  There is apparent inconsistency in the two legislations.  The word ‘establishment’ in Section 2 (ix) means any office, firm, factory, society, undertaking, company, shop, premise, establishment in the Province of Sindh which employs workman “directly or through a contractor” for the purpose of carrying on any business or industry and includes all its departments and branches whether situated in the same place or in different places having a common Balance Sheet.  This definition of the term ‘establishment’ is in direct conflict with Section 2 (x) of IRA 2012 legislated earlier by the Federal Government and still in force.  It is unfortunate that ever since IRO 1969 was promulgated till this date, there has been conflicting decisions and interpretations as to the meaning of the term ‘establishment’.  In Civil Appeal No. 206 of 1988 titled National Bank of Pakistan vs Punjab Labour Court No. 5, Faisalabad, Supreme Court of Pakistan  interpreting the term ‘establishment’ in the context of a branch of a Bank, have held that the branch of a Bank is an establishment by itself.  Earlier Division Bench of the High Court of Sindh in the case of Muhammad Aqil vs Sindh Labour Appellate Tribunal and another (PLJ 1974 Kar 252) observed that the expression establishment include not the whole of the establishment of an employer but each of them individually and that an employer may have more than one establishment for carrying his business or for the purpose of industry.  So also in the case of Ehsan Sons Limited (1987 PLC 390), Grindlays Bank (Lloyds Branch) case (PLJ 1980 Lahore 523) and HBL case (NLR 1987 89 Labour 93), High Courts of Sindh and Lahore were of the view that establishment can have more than one office or branch and the Supreme Court of Pakistan in unreported case of Rice Export Corporation of Pakistan Employees Union Front in Civil Appeal No. 202-K/1991 have held that above judgments are consistent with the judicial consensus obtained in Pakistan.  Under the circumstances, it was expected that legislature before passing SIRA 2013 should have examined the entire case law on the subject, and the draftsmen should have noticed not only judicial pronouncements of the Apex Court and High Courts, but also ensured that it was not in any way in conflict with legislations in other Provinces or at the Centre.  This definition, in due course of time will lead to being challenged both before the Apex Court and in the High Court.

Section 2 (xv) has defined the term ‘industrial dispute’ as meaning any dispute or difference between employer and employer or between employer and workman and between workman and workman which is in connection with the employment, non employment, terms of employment or conditions of work.  Needless to mention that ever since the concept of Collective Bargaining Agent found judicial recognition, and incorporated in IRO 1969, and thereafter, it has consistently been held, including Section 53 of present Sindh Industrial Relations Act 2013, that no industrial dispute shall be deemed to exist unless it has been raised in the prescribed manner by CBA or an employer.  The definition of the term ‘industrial dispute’ in Section 2 (xv) is thus, not only in conflict with Section 53 of the said Act but with the other provision of Sindh Industrial Relations Act 2013.  We cannot conceive of an industrial dispute between employer and employer or between workman and a workman.  There also cannot be industrial dispute between an employer and workman, for it is a trade union which is determined and certified as CBA and not a workman.  The correct definition of the term ‘industrial dispute’ under the circumstances should have been as follows:-

“Industrial dispute means any dispute or difference between CBA and employer which is connected with the employment, non employment, terms of employment or the conditions of work of workman and is not in respect of a pre-determined or pre-existing right guaranteed or secured either to the CBA or employer by, or under any law, settlement or award, for the time being in force.”

The term ‘industry’ has been defined in Section 2 (xvi) to mean any business, trade and manufacture, calling, service including fishing, mining and agriculture and installation, exploration, processing, printing and electronic media, employment or occupation of producing goods and services for sale other than those set up for charitable purposes.  No doubt this definition is improvement over the earlier definition of the term ‘industry’.  Still further the concept of industry under Labour Jurisprudence is economic activities of producing goods and material services.  Here once again although fishing and agriculture has been included in the definition of the term ‘industry’, yet poultry farming, livestock has been overlooked.  Same needs to be incorporated in the said definition.

The term ‘lock-out’ has been defined in Section 2 (xix) of SIRA Act 2013 to mean closing of place of employment or part of such place, suspension of whole or part of work by an employer, refusal absolute or conditional by employer to continue to employ any number of workman, when such closing, suspension or refusal is in connection with an industrial dispute or is intended for purpose of compelling workman to accept certain terms and conditions of or effecting employment.  Once again this definition is far-fledged and confusing.  Termination of service, even if, wrongful is not a lock-out.  The definition of the term lock-out should thus be as under:-

“Lock-out means closing of the place of employment or part of such place, suspension wholly or partly of work by an employer, refusal absolute or conditional by employer to continue to employ any employee by him except a workman discharged, dismissed, or otherwise terminated from service or who has retired or has reached the age of superannuation or otherwise severed all his connection with his employer, when such closing, suspension or refusal occurs in connection with an industrial dispute or is intended for the purpose of compelling such person employed to accept certain terms and conditions or effecting employment.

The term ‘office bearer’ has been defined in Section 2 (xx) to mean in relation to trade union, any member of the executive but does not include an auditor or legal advisor.  It should be further provided in this definition that a person will not be treated as an office bearer of the union if he is not a workman or still further full time paid trade unionist within the limits of law.  This will go a long way to eliminate mushroom growth of trade unions in this country and exploitation of workers by political party and or those who are neither workman in the establishment with which trade union is formed and will eliminate, in due course of time, professional labour leaders out to exploit workers and also eliminate those persons who are not enrolled as Advocate within the meaning of Labour Practitioner and Bar Council Act, 1973.

The term ‘strike’ has been defined in Section 2 (xxix) to mean cessation of work by body of person acting in combination and concerted refusal or refusal under common understanding of any number of persons so employed to continue work or accept employment.  This definition is also defective.  The term ‘strike’ as defined in the Act gives an impression that even if there is five percent of the normal work, it will not constitute a strike.  The suggested text of the definition of the term ‘strike’ should thus be as under:-

“Strike means cessation of work, absolute or partial, by body of persons employed in any establishment or part thereof, acting in combination either wholly or partly or concerted refusal wholly or partly under a common understanding of any number of persons, for any duration of time who have been or employed to continue to work or to accept employment.”

The term ‘settlement’ in Section 2 (xxviii) has been defined to include a settlement between employer and his workman.  Repeatedly it has been pointed out that only a CBA can raise an industrial dispute and an employer is only required to conclude settlement with the CBA and not with a workman.  The suggested text of the definition of the term settlement thus should be as under:-

“Settlement means a settlement arrived at in course of conciliation proceedings and includes an agreement between employer and CBA arrived at otherwise than in the course of conciliation proceedings, where such agreement is in writing and has been signed by the parties thereto, in such a manner as may be prescribed and copy thereof has been sent to the Government of Sindh, Conciliator and such other persons as may be prescribed.”

The term ‘Trade Union’ as defined in Section 2 (xxx) also includes combination of employers.  The concept of a trade union as developed over the years through Labour Jurisprudence is combination of workman to have their rights enforced against employer once the said union is determined as CBA.  The definition of the term ‘Trade Union’ should thus be as under:-

“Trade Union means any combination of workers or workman formed primarily for the purpose of further regulating and defending the interest and rights of workman in any industry or establishment or apart  thereof and includes a Federation of two or more  than two of such Trade Unions.”

Finally the term ‘worker’ and ‘workman’ has been defined in Section 2 (xxxii) of the Act.  Present definition provides that a person not falling within the definition of employer is a workman.  This is not the concept developed in Labour Jurisprudence.  There can be a situation where there is an employer, workman and person employed who is neither an employer, nor a workman.  The suggested text of the definition of ‘Worker’ or ‘Workman’ should therefore be as under:-

“A worker and workman means any person employed in any establishment or part thereof or in any industry, to do skilled or unskilled, manual or clerical work as his main and primary duty for remuneration or reward employed by the employer other than a person employed by the contractor where terms of employment be expressed or implied and for the purpose of this Act does not include any person working in the managerial, administrative, directional, controlling or in a supervisory capacity working either in the establishment or any part thereof.”

Section 3 of the Sindh Industrial Relations Act 2013 provides for Trade Union and Freedom of Association.  This provision of law has recognized Freedom of Association as enshrined in Article 17 of the Constitution of Pakistan, 1973 read with ILO Convention 87 and 98 which provides for Freedom of Association and Right to Organize Collective Bargaining.  This provision of law is thus in conflict with Section 1 (3) of the Sindh Industrial Relations Act 2013 which specifically excluded large category of employees from the ambit of Sindh Industrial Relations Act 2013.  However, a welcome feature of proviso to Section 3 (i) is that in establishment where women are employed, trade union shall include women in the executive of the said Trade Union in the same proportion as employed in the establishment.  The law no doubt provides that every Trade Union shall frame its own Constitution but there is no provision incorporated in Section 3 of the Act to the effect that the Union shall be duty bound to provide copy of the Constitution with all amendments made there from time to time duly approved by the Provincial Registrar of Trade Unions to the employer.  This is necessary to ensure that Trade Union functions not only within the ambit of law but also within the ambit of registered Constitution of the Union.

Section 4 of the Sindh Industrial Relations Act 2013 provides that any Trade Union under the signatures of its President and Secretary can apply to the Registrar of Trade Unions for the Registration of Trade Union under this Act.  Conciliation, Registration of Trade Union and Registration in respect of factory under the Factories Act are the three main functions presently being performed by the Provincial Directorate of labour.  Each of these functions presently are under the overall control of one Director of Labour.  In order to ensure registration of union, conciliation proceedings and registration and inspection of factories are separately and independently performed, there must be devolution of power.  This will, to a large extent control the present unbridled, arbitrary and discretionary powers available with the Director of Labour in the Province.  Thus conciliation, registration of trade union and registration and inspection of Factories be separated each under separate Director, who will be directly responsible to the Secretary Labour of the Province.

Section 6 of the SIRA 2013 in terms of Section 6 (1) (d) provides that number of persons forming Executive shall not exceed prescribed limit and shall include not less than eighty percent from amongst workmen actually engaged or employed in the establishment or group of establishment or industry for which trade union has been formed.  Earlier outsiders condition was seventy five percent.  If intention of the legislature is that eighty percent of the Executive of a union should be worker in the establishment and rest of twenty percent outsiders be anyone, then such interpretation can possible lead to a situation where employer will treat himself as an outsider in the twenty percent quota and hold office either of the President or General Secretary of the Union in his establishment and thus defeat and frustrate very purpose and essence and spirit of formation of trade union.  Needless to mention the General Secretary alone can serve charter of demands, raise industrial dispute and conclude settlement.  He alone can initiate proceedings either in the Labour Court, and or Labour Appellate Tribunal.  Incorporation of this provision will result in chaos and confusion.  A person who has been dismissed, terminated from service retrenched and whose dismissal, termination or retrenchment is pending determination either before the Labour Court and or Labour Appellate Tribunal cannot be deemed to be an employee in that establishment, and as such, he will no more be a worker within the ambit of eighty percent Executives from amongst the workmen “actually engaged or employed” as mentioned in Section 6 (1) (d) of SIRA 2013.  The Supreme Court of Pakistan   in the case of Mir Alam & others vs Registrar of Trade Unions reported in 2008 PLC 239 at 241 and 242 in the context of participation of a terminated employee in a Ballot for determination of CBA has held that an employee terminated from service could not be deemed to be a workman of an employer unless the case is decided in his favour and he has been reinstated.  It is recalled that Section 8 (2) (a) – Explanation to IRO 2011, it was specifically provided that dismissed, terminated, retrenched worker or such category of worker whose cases are pending before the Court of competent jurisdiction shall be deemed to be employed person.  Unfortunately even this explanation or saving clause has been deleted in SIRA 2013.  It may be recalled that under Section 27-B of Banking Companies Ordinance 1962, the law has restrained an outsider from becoming a member or an office bearer of trade union.  There is no repugnancy of this law to Article 17 of the Constitution as held by Division Bench of Karachi High Court in the case of Bank of America Employees Union vs Federation of Pakistan, reported in 2003 PLC 143.

Section 7 of the Act provides for disqualification for being office bearer of a trade union.  This law provides that a person who has been convicted of offence under Section 70 or heinous offence under Pakistan Penal Code shall be disqualified from being elected as or  from being office bearer of a trade union.  This means that even if a worker has been dismissed from service on gross acts of misconduct like assaulting his superior, resorting to illegal strike or slowdown in work, committing theft, fraud and defalcation of money can still, notwithstanding his case being dismissed by the court of law, can nevertheless claim entitlement to be elected an office bearer of the union in the twenty percent outsiders quota.  High Court of Sindh and Lahore have interpreted that even twenty percent outsiders quota should be in the category of workman, though not in the employment of the same establishment.  This provision of law, in due course of time, is liable to create further chaos and confusion in industrial relations and need to be rectified at the earliest.

Section 9 of the Act deals with registration of the union.  This provision of law leaves it exclusively to the subjective satisfaction of Registrar with no outside interference in matters pertaining to registration of union.  Such registration of union should be after due diligence where employer’s assistance be also availed to the extent of claim made by the applying union. The functions of Registrar of Trade Unions is quasi judicial.  He has to pass speaking order either whilst effecting registration of a trade union or even whilst refusing to register trade union being a public functionary.  Being Judicial Officer, he should not be a part of the Executive, which deals with either conciliation proceedings or even registration of a factory and inspection of factories. 

Furthermore in terms of Section 10 of SIRA 2013 right of appeal to the Labour Court has been provided only to an aggrieved trade union.  There is no right of appeal against wrongful registration of a trade union to an employer.  This provision of law has and will continue to make Registrar of Trade Union a medieval emperor out to blackmail the employer on the terms dictated by him on pain of registering a trade union.  It is not only essential for the Registrar of Trade Union to exercise due diligence and verify facts before registering any trade union, but every effort be ensured that due diligence and verification of facts be based from any source, and input could well be also from the employer.  There is no provision of law for Registrar to give reasons either for registration of trade union or refusal to register a trade union.  Such exercise of arbitrary and whimsical power either to register a trade union or refusal to register a trade union will come to a large extent be curtailed if due diligence is affected, and employer is equally associated in matters pertaining to registration of a union being proper and necessary party. Section 10 of the Act further provides that prior permission of Registrar is to be obtained if office bearer of a trade union of workmen under registration is either to be transferred, discharged, dismissed or otherwise punished during pendency of application for registration of trade union.  This provision of law lend support to the inference that the functions of Registrar is judicial or at best, quasi judicial, functions and he should be separate from Executive and his appointment be made in due consultation with Chief Justice of High Court of Sindh.  Appropriate provisions be incorporated, as such, in terms of Section 10 of SIRA 2013.

The law pertaining to cancellation of registration of a union is incorporated in terms of Section 12 of the said Act.  It is provided that if a union contravenes or has been registered in contravention of any of provisions of the Act or rules framed there under or if a trade union contravenes any of the provision of its Constitution or otherwise made in its Constitution any provision which is inconsistent with the Act, then registration of such union is liable to be cancelled.  No doubt in terms of Section 11 it is provided that certificate of registration of trade union is a conclusive evidence that it is registered under the Act.  However, this provision only raises a presumption.  The presumption is restricted and confined only to registration of a union, and it is not to be extended to the presumption that such registration has been effected in conformity with law or that it could not be challenged before any other judicial forum.  Such a challenge can only be possible, if Registrar passes a speaking order giving reasons and grounds for registration of the union and or refusal to register a trade union and also if employer is associated in matters pertaining to registration of such union.  As a necessary corollary it follows that unfortunately Section 12 of the SIRA 2013 only empowers Registrar of Trade Union and no one else to apply to the Labour Court for the cancellation of registration of union.  No Registrar who has registered a trade union will own and claim that the registration so effected by him was in contravention of the provision of the Act or the Rules framed there under.  This is not within the radar of our executive or quasi judicial officer.  Admission of wrong is not in the psyche of our Executive.  Clause (b) of Section 12 dealing with contravention of provision of its Constitution and has been provided ever since 1969 IRO but till this date no RTU has taken any action applying for the cancellation of registration of a trade union on the ground that the union has contravened the provision of its Constitution.  Likewise claiming that if Constitution or any provision of Constitution is inconsistent with law, its registration is liable to be cancelled makes no sense since Constitution of a union is to be registered, and duly approved by the RTU.  Every amendment made in the Constitution has to be examined by the RTU before its approval.  There is therefore redundancy in claiming that registration of a trade union will be cancelled if there is made in the Constitution any provision in consistent with the Act and rules.  If there is such inconsistency, the RTU, ipso facto, will not grant any approval.  Furthermore there is nothing in the provision of law which provide, that once the RTU apply to the Labour Court for cancellation of registration of the union, then he cannot subsequently withdraw such application.  Experience has shown that at least in Karachi, there have been cases where Registrar has applied to the Labour Court for cancellation of the registration of the union, but either due to political pressure from the party in power and or pressure from the union or the Federation, the application for cancellation of registration of union have subsequently been withdrawn.  Invariably in most cases employer is not a party to such application for cancellation of registration of the union.  This leaves the matter entirely within the arbitrary and despotic will of the Registrar to apply for withdrawal of cancellation of registration application against the union.  Likewise there is no provision in law which makes it incumbent, that if registration of a union is ordered to be cancelled by the Labour Court, then office bearers of such union stand disqualified either from being elected or holding any other office in any other union in the same or any other establishment.  These provisions of law should necessarily be incorporated in terms of Section 12 of SIRA 2013.  Experience has shown that for years altogether in some cases trade unions do not submit either Annual Returns duly audited by Chartered Accountants, nor elections every two year, as provided in their Constitution are held.  It should be provided in law that Annual Returns to be submitted by the union should be audited by the Chartered Accountants from the amongst panel appointed by the Government and such Annual Returns should be submitted within three months of the close of the accounting year and still further elections to the union be held within fifteen days from the expiry of the term of office of the office bearers of the union.  Consequence of non compliance of these provisions be incorporated in law. If there are provisions in the Constitution of the Union that the office bearer can hold office for more than one term, the same be specifically be made part of the parent law.  There is no reason why a provision of not being elected office bearers of trade union for not more than two terms be not incorporated in SIRA 2013.  If President of the country cannot hold office for more than two terms, there is no reason why certain set of office bearers treat the union as their exclusive heritage and monopoly, and continue for all times to come, to hold office in a trade union.  This, to a large extent, discourages other workers from becoming office bearers of the union.  Necessary incorporation in law be thus made.

Section 13 of SIRA 2013 provides that a trade union aggrieved by order of the Labour Court may prefer an appeal to the Tribunal.  Similarly trade union aggrieved by the conduct of Registrar in delay or refusal to register a union may prefer an appeal to the Labour Court.  Unfortunately, presently appeal is to be filed in the Labour Court if Registrar refuses or delays registration of a trade union only by the aggrieved union.  More than one right of appeal has been conferred to aggrieved trade union, first to file an appeal in the Tribunal if the Labour Court rejects earlier appeal filed by such a trade union in the Labour Court.  As a plea has been made above that apart to applying for cancellation of the registration by the Registrar Trade Union, employer should also be given the power of applying for cancellation of registration of union which has contravened any provision of law, rules framed there under or has contravened any provision of union Constitution.  In the same way, employer should equally be given right to challenge decision of the Labour Court in the Tribunal and the action of RTU before Labour Court and to this effect in case they are aggrieved by any conduct of the Registrar of Trade Union. Necessary incorporation be made in the law.

Section 14 of SIRA 2013 provides that Government shall appoint as many persons as Registrar and even appoint more than one Registrar for any particular area.  There is no provision in law that the Government should appoint such Registrar Trade Union in consultation with Chief Justice of the High Court of Sindh.  Such appointment of a Registrar Trade Union presently is in violation to the recent judgment of the Supreme Court of Pakistan  in C.P. No. 53/2007 titled Shaikh Riaz-ul- Haq, Advocate Supreme Court vs Federation of Pakistan where the Apex Court relying on Al-Jehad Trust case (PLD 1996 SC 324) and Mehram Ali case (PLD 1998 SC 1445) has made consultation mandatory and present provision in law is not in accordance with the Constitution of Pakistan and decisions of Apex Court.  No criteria as to the said Registrar having any minimum educational qualification, including that of law, has been provided in Section 14 of the Act.  In due course of time quo-warranto petitions are liable to be filed against such appointment of Registrar Trade Union, hence urgency to amend law accordingly.

Section 15 of the SIRA 2013 provides for power and functions of the Registrar of Trade Unions.  In terms of Section 15 (2), the Government has been conferred power to authorize Registrar even to register an industry wise trade union and federation at the provincial level.  The term ‘industry wise trade union’ has not been defined in SIRA 2013.  However, Section 2 (xviii) of IRA 2012 has defined ‘industry wise trade union’ as meaning a trade union having its membership in more than one province in a group of establishment owned by one employer.  This provision of law is ultra vires and the principle laid down by the Apex Court in the case of Air League (2011 SCMR 1254) and also the Constitution of Pakistan.  It is also in direct conflict to Article 144 of the Constitution and Section 1 (2) of SIRA 2013 which provides that the law extends to whole of Province of Sindh making any provision extending sphere of law beyond Province of Sindh to be ultra vires the law and Constitution of the country.

Section 16 of the Act provides for incorporation of a registered trade union and mentions that every registered trade union shall be a body corporate by the name under which it is registered.  It has been observed that there are certain multinational organizations who have their name registered and incorporated as an international Trade Mark.  Use of that Trade Mark is only restricted and confined to be used by the body in whose favour such a registration has been effected.  Using that name and associating it with the name of a trade union is a direct infringement of Registration, Patent and Trade Mark law.  This aspect of the matter needs serious reconsideration, as of late large number of multinational organizations have taken exceptions to the use of their registered patent and trade mark name to be used unauthorisedly by the trade union applying for registration or functions of a trade union in any organization or establishment as the case may be associating use of such registered Trade Mark with the union.

Section 17 and 18 of the Act deals with unfair labour practice on the part of the employer and workman.  This phrase “Unfair Labour Practice” is a part of the wider subject on industrial relations and is very flexible and capable of being stretched far too wide or limited within narrow confinement.  This problem is delicate and difficult to be dealt with.  Unfair labour practice concept arose out of a struggle waged by trade unions and unfair labour practice is on the part of employer is provided so as to remove hurdles and obstacles in the free formation, registration and functions of a trade union and right to bargain collectively.  Invariably this concept of unfair labour practice, although in existence, even in the Trade Unions Act 1926 as adopted in Pakistan in 1947 and even thereafter in the West Pakistan Trade Unions Ordinance, 1968, the same found growing use in IRO 1969.   Unfair Labour Practice gained awakening only with the establishment of National Industrial Relations Commission in the year 1972 and onwards.  NIRC (Procedures and Functions) Regulation 1973 were framed by NIRC in consultation with the Federal Government.  Now an experienced and well versed in law Supreme Court retired Judge has been appointed as Chairman of NIRC.  It is expected that review of NIRC (Procedures & Functions) Regulation 1973 are made and new regulations framed in consultation with the Chief Justice of Pakistan.  It is also suggested that in keeping with the essence and spirit of one of the functions of NIRC to advise the Government in respect to the education of workers in the essential of trade union, the NIRC initiate and organize a Conference or Seminar to examine the concept of Unfair Labour Practice both at the Centre and in the Provinces as also education of workers in essential of trade unions.  Assistance from the report of National Commission on Labour in India in the year 1976 headed by retired Chief Justice, P.B. Gajendragadkar and subsequent report of Second National Commission on Labour in India established by Mr. Vajpayee, the then Prime Minister of India in the year 2002 may serve as guideline.  ILO Labour Survey Commission report in 1951, and the earlier Royal Commission on Labour report in 1931 can also provide guidelines.  So also Regey Committee’s recommendations of 1943 in pre-partition India can be of assistance.  The institution of NIRC will have to be reactivated.  Time and again plea for similar National Commission on Labour in Pakistan has been made.  Unpublished Justice Shafi-ur-Rehman and Justice Attaullah Sajjad report available with Ministry of Labour can also provide us useful guidelines and assistance as these learned Judges have given their valuable inputs on this subject.  However, a detailed analysis of unfair labour practice committed both by employer and workman have to be threshed out and its misuse and abuse has to be avoided.  Section 23 of SIRA 2013 makes provision for submission of Returns to the audited accounts of the union.  Non submissions of such Returns within stipulated period and violation if detected and its consequences by the Registrar from these accounts have to be incorporated in law as presently none exists.

Section 24 of the Act provide for concept of Collective Bargaining Agent.  It is provided that if there is only registered trade union in any establishment or a group of establishment that trade union if it has not less than one third of the total number of workers employed in such organization, be certified as CBA, upon an application made in this behalf by the RTU as CBA.  This provision of law is not happily worded.  An impression is gathered that  if once trade union is registered and certified as CBA and there is no other trade union in the establishment, then for an indefinite period and or for all times to come thereafter, the said union shall be treated as CBA.  Furthermore there is nothing in law to suggest that one third of the total number of workman concept should be ascertained by Registrar, only once at the time of CBA certification or after every two years, as we cannot rule out the possibility that the only registered trade union in the establishment on the eve of applying for CBA certificate had one third of total number of workmen employed in the establishment as its members but thereafter after a lapse of two years it had less than one third of the total number of workmen in the establishment as its members.  It is therefore incumbent that just as certificate of CBA is valid for two years if it is determined on the basis of secret ballot in establishment with more than one union, such CBA certificate be for two years, much in the same way, even if there is only one registered trade union, certificate should be for two years and thereafter on expiry of the said term, the union should again apply to register trade union, claim and establish more than one third of the total number of workman employed in such establishment to be its members and obtain a fresh certificate of CBA from Registrar.  Amendments in law be thus made.  Presently, there are in certain establishments, more than one registered trade unions, yet first union having obtained certificate of CBA more than 30 to 35 years back continue to claim the said status of CBA and the Registrar is indifferent to such claim, whereas there is no provision in the law which entitle the employer to challenge such a situation except to institute Constitution Petition in the High Court.  The law in terms of Section 24 (6) provides that the employer is required to provide list of workmen not less than three months in service and other details for determination of CB, but provide that it is the function of a trade union claiming status of CBA. The employer, under no circumstances be expected or required to bear any expenses for the conduct of such ballot for determination of CBA, between the unions. The term for such CBA should be two years and every Registrar must ensure that within one week of the expiry of the term of such a CBA, a fresh ballot is conducted so that there is no vacuum, and industrial relations is not jeopardized and industrial peace and harmony is maintained.  Leo Tolstoy, the Russian Writer has rightly said: “We lost because we told ourselves we lost.”

Section 27 of SIRA 2013 provides for union deductions by way of check-off at source, by the employer and paid in the accounts of the union to be maintained with the branch of National Bank of Pakistan, Sindh Bank, Post Office or any Saving’s Bank.  If Trade Unions in this country are to survive financially, unions subscription should be a voluntarily act of the members to pay union subscription directly to the Unions.  Under no circumstances employers should be  associated to act as an agent on behalf of the CBA to deduct from the wages the subscription and deposit  the same in the account of the Union  The law which provides  for  union subscription is altogether silent about collections of union directly made illegally by the Union, without giving any receipt to its members for the purpose of pursuing  litigations in the Court, paying fee to the counsel or Labour Leader and collecting money to prolong, in most cases,  illegal strikes and for   perpetuating Gherao and Dharna , all of which are not recognized in law.  No efforts  whatsoever has been made to ensure that the collected union subscription  are strictly streamlined and utilized through legislative means and under no circumstances subscription given by the workers are  to be utilized for  unlawful means in negation to good labour management relations.

The condition that CBA should only maintain the account with a branch of NBP or Sindh Bank is not fair.  All Banks are registered with State Bank of Pakistan and it should be open for the union to request the employer and provide them with the name of the branch of the Bank of their choice where union deductions is to be effected assuming the Government maintain that the employer deduct the payment from the wages of the workers.

In terms of Section 28, 29 & 30 of SIRA 2013, provisions have been made for Shop Steward, Workers Management Council and Workers Participation in Management.  Unfortunately, over the past four decades, none of these  bodies  have been instrumental  or played an effective part in bringing about industrial peace and harmony  for better relationship between employers and employees.  Rather it is  creating a new breed of persons who claim to be  a member of these bodies and  therefore exempt from performance of their normal duties and claim full salary and benefits from the employers.  These are institutions more for paper reading rather than making effective contribution towards labour management relationship  and by misuse of these  provisions of law,  unfair bad labour practice both on the part of the employer and  workmen   are encouraged.

Section 34 of the SIRA 2013 deals with redressal of individual grievance.  The grievance should be restricted to pre-determined or pre-existing rights guaranteed or secured right of an individual worker.  Furthermore Section 34(7) provides that Labour Court is to adjudicate and determine individual grievance of such worker.  This use of nomenclature “Adjudication and Determination” is not happily drafted.  The well recognized concept in Labour Jurisprudence to adjudicate and determine means that it is the Labour Court who has to adjudicate and determine an industrial dispute raised either by the employer or CBA.  Instead of use of the words adjudication and determination in Section 34(7) of the Act, language of this sub section should read as under:-

“In enforcing pre-determined and pre-existing right guaranteed to an individual worker, the Labour Court shall go into all the facts of the case and pass such orders as may be just and proper in the circumstances of the case.”

Furthermore in terms of Section 34 (10), it is provided that workers having common grievances arising out of common cause of action may make a joint application to the Labour Court.  Even this provision of common grievance arising out common cause of action is misconceived.  No two individual workers can possibly have common grievance arising out of common cause of action.  Rights have to be pre-determined and pre-existing.   It is to be enforced during pendency of the award or settlement or even law for the time being in force.  The common grievance application means merely signing of the application and thereafter abstaining from appearing in the Curt and authorizing only one individual to record the evidence which all makes a mockery of the law.  This clause (10) of Section 34 be accordingly be deleted and or suitably amended.

Section 35 of the Act deals with negotiation relating to the industrial dispute either raised by the CBA or employer.  Sub clause 3 of Section 35 refers to ‘failure of bilateral negotiations’.  Experience has shown that invariably there is nothing on record to indicate failure of such bilateral negotiations.  It should either be incorporated in the law that either CBA or employer has confirmed failure of bilateral negotiations in writing or even if employer feels that further bilateral negotiations continue but the CBA is of the view that no useful purpose will be served by continuing with bilateral negotiations, there must be some positive indication in writing incorporated in clear terms the intention of CBA to declare bilateral negotiation of failure so that appropriate notice of strike or lock-out may be served by the CBA or the employer as the case may be.

Section 39 of SIRA 2013 deals with conciliation proceedings, whereas Section 40 of the said Act deals with Arbitration.  It provides that after conciliation fail, Conciliator shall try to persuade the parties to refer the dispute to an Arbitrator.  There is nothing on record to show any form to be framed in the Regulation under the said Act as to the contents and ingredients of such failure of conciliation or arbitration.

Section 41 of SIRA 2013 that if no settlement is possible, the workers may go on strike, or employer declare a lock-out.  It is essential that there should be something on record to indicate failure of conciliation proceedings. In the repealed IRO 1969 and the rules framed there under, it was specifically provided that failure of conciliation proceedings will be in terms of certificate format where was provided in the Industrial Relations (Sindh) Rules.  There is no such provision in law leading to the inference on the one hand by a claim on the part of the CBA that conciliation and arbitration efforts have failed, whereas the same being denied by the employer to the effect that it has not been failed.  The Labour Court before whom the matter is to be determined has to thereafter rely on conciliation proceedings or words of the Conciliator.  In order to bring about smooth end to this impasse, failure of conciliation be specifically be provided in law and the rules that are to be framed under SIRA 2013 should provide the format under which the Conciliation Officer is to issue a certificate of failure of conciliation proceedings.

Section 42 of the SIRA 2013 deals with strike and lock-out in public utility service.  List of public utility service as incorporated has been identified in the Schedule attached to the said Act.  Whereas right to form Association including  Trade Union is a Fundamental right, the guarantee in terms of Article 17 of the Constitution of Pakistan is limited.  Right to strike is not a Fundamental Right.  This right to strike is available under one of ILO Convention ratified by Pakistan.  It is therefore suggested that there should be a moratorium to strike or lock-out at least in the public utility service like institutions involved in generation, production, manufacture or supply of electricity, gas, oil and water to the public be prohibited.  So also strike in hospital, ambulance service, fire and fighter service, any system of public conservancy or sanitation, railway, Airways, postal service, telephone and telegraphic service be prohibited.  Unfortunately item No. 7 of the Schedule to public utility service mention “Dry ports”.  It is hard to appreciate the wisdom of treating Dry Port as public utility service, whereas ports where import and export of goods including food grains and fertilizers are loaded and unloaded, petroleum and other items imported or exported, have not been identified as public utility service.  Watch and Ward staff and security service in any establishment is included as a public utility service in the Schedule.  Members of Watch and Ward Staff or chowkidars are given and eligible to become members of a trade union.  This being so, if CBA calls for strike, then watch and ward staff and security service are expected to man the establishment from being caused with any major damage.  Here conflict of interest will arise. Therefore either watch and ward staff and security service should altogether be excluded from the ambit of Industrial Relations Law or it should be excluded from public utility service.  Since strike and lock-out are not Fundamental Rights, it is suggested that for the next five years there should be moratorium on strike and lock out so that industrial peace and harmony is resorted in industrial and commercial establishment, and the economy of the country is revived and placed in right direction.

Section 43 of SIRA 2013 provides for application being moved to the Labour Court either by the CBA or employer for redressal of grievance of right guaranteed and secured under any law, settlement or award.  Once again this section has not been happily drafted.  The correct text should be as under:-

“Any CBA or any employer may apply to the Labour Court for redressal of any pre-determined or pre-existing rights guaranteed or secured to the said CBA or the employer by or under any law, award or settlement for the time being in force.”

Section 45 of SIRA 2013 provides for appointment of Presiding Officer of Labour Court.  Unlike provision of IRO 2002 where such appointment of a Presiding Officer of Labour Court was to be made in consultation with Chief Justice of Sindh High Court, no such provision exists in the present law.  This is in negation to the recent judgment of the Supreme Court of Pakistan in Civil Petition No. 53 of 2007 titled Shaikh Riaz-ul-Haq, Advocate Supreme Court vs Federation of Pakistan.  Labour Court Judge are District Judge.  Their appointments should be in consultation with the Chief Justice of Sindh High Court.  Furthermore only Senior District & Session Judge be appointed Presiding Officer of the Labour Court.  No additional District Judge be appointed as Presiding Officer of the Labour Court.  Necessary incorporation in the provision of Section 45 of Act in this behalf be made.

Section 46 of SIRA 2013 provides for procedure and power of Labour Court.  Sub section 2 of Section 46 has provided that a Labour Court for the purpose of adjudication and determination of any industrial dispute be deemed to be a Civil Court and shall have same power as are vested in such Court under Civil Procedure Code 1908.  Labour Courts are Courts for all intents and purposes, they perform both civil and criminal functions and for the purpose of adjudication and determination and industrial dispute or for enforcement of any pre-determined and pre-existing rights such civil court should have all the power of Courts which a District Court Judge has.  It is imperative that after the written statement is filed by the respondent, issues be framed, and thereafter evidence be recorded viva voce unless for specific reasons recorded in writing, Labour Court decide to dispense with recording of evidence viva voce and directs such evidence to be placed on record through pre-typed affidavit in evidence.  Court must ensure that such affidavit in evidence are strictly in accordance with law.  Affidavit should be identified by Legal Practitioner as defined in law.  It is provided in law that no court fee is payable.  Reasons for this is hard to appreciate.  One of the main reason as to large number of frivolous litigations are instituted in the Labour Court are that no fee is payable to the litigant.  Not only there no court fee even for exhibiting, recording or obtaining any document from the Labour Court.  The normal practice of court fee and obtainment of documents and records from the Court against court fee, payment as understood in the High Court and also in the District & Session Court should be followed in Labour Courts proceedings.

Section 47 of the Act provides that award or a decision of the Labour Court shall be given in writing delivered in open court.  Invariably it is noticed that oral announcement of the decision is made by the Presiding Officer with copy of the decision neither dictated, typed, or signed.  It is for this reason that although application for copies are made the same day, decisions are delivered after considerable delay.  There are numerous decisions of the High Court to the effect that the decision orally announced by Presiding Officer of the Labour Court with the copy neither dictated, typed or signed, does not announcement of decision. .  Necessary incorporation to this effect be made in terms of Section 47 of the Act to remove this anamoly.  Furthermore it is provided in law that copies of the decision are to be forwarded to the Government and within 30 days these judgments would be published by the Provincial Government in the official gazette.  In 54 years of our practice in the field of Labour Laws, we have still to come across one single instance where Provincial Government has published decision of the Labour court in the official gazette.  Since this provision of publication is directory and not mandatory, it should altogether be deleted from the statute.

Labour Appellate Tribunal are to be constituted by the Government of Sindh through Notification in terms of Section 48 of SIRA 2013.  Under IRO 1969 the Judge of the Labour Appellate Tribunal was identified as a Chairman, whereas now he is identified as Member.  It is recalled mentioned that more than one Tribunal may be constituted in the province of Sindh.  Territorial limit of the members who will exercise jurisdiction are to be notified.  In Punjab, there are two Labour Appellate Tribunals, one stationed in Lahore which covers Lahore, Rawalpindi, Faisalabad and Sargodha, whereas Second Punjab Labour Appellate Tribunal is permanently stationed at Multan, covering Southern Punjab and other District.  For no apparent reason and inspite of repeated representation made to the Provincial Government in Sindh, there is only one Labour Appellate Tribunal, and work both of appeals and revisions are accumulated.  Furthermore no age limit is provided for a Member of the Tribunal except that he is or has been a Judge or Additional Judge of the Sindh High Court. It should necessarily be incorporated in law that there be two Tribunals and one of the sitting Judge of the Sindh High Court at Karachi, whose territorial jurisdiction should be the decisions of the Labour Court cases at Karachi.  The second Sindh Labour Appellate Tribunal be stationed permanently either at Hyderabad Circuit or the Sukkur Bench of the Sindh High Court of a sitting Judge of the High Court.  It is high time Government after elections takes serious view of the matter and these suggestions are incorporated in Section 48 of SIRA 2013.

It has been noticed in SIRA 2013, as was also earlier incorporated in the other earlier Industrial Relations Law, that only a party raising industrial dispute may not resort to strike or lock-out on failure of conciliation and only side rising the demand may approach the Labour Court and  may refer the matter to Labour Court for adjudication.  This country has passed through crisis over the last few years. We cannot afford luxury either of strike or lock-out. It should therefore be incorporated in the law that notwithstanding the fact that the employer or the CBA has raised industrial dispute, on failure of conciliation proceedings any party to the said dispute may apply to the Labour Court for adjudication of the industrial dispute.  In this way there will be no disruption in production and industrial peace will be maintained and matter amicably adjudicated by the Labour Court, subject of course to right of appeal in the Sindh Labour Appellate Tribunal.

Section 52 of the SIRA 2013 provides that certain matters are to be kept confidential.  It is provided that there shall not be included in any written award or decision any information obtained either by the Registrar, Conciliator, Labour Court, Arbitrator or Tribunal in the course of any investigation or enquiry as to trade union or as to any individual business, expect where a request in writing is made so as to treat such information as confidential.  This provision of law, with all respect is in conflict to Article 19-A of Constitution of Pakistan which deals with Freedom of Information. Right to Information has been inserted by the Constitutional Eighteenth Amendment Act 2010 and it provides that every citizen shall have the right to access to information in all matters of public importance subject to regulation and reasonable restriction imposed by law.  In rare and exceptional circumstances, the Courts after the 18th Amendment have restrained itself or any other Court from access to information.  The recent example being information collected through the report of Lal Masjid incident which has been ordered by the Apex Court to be published, as also the payments made from the secret fund by the Ministry of Information etc.

Section 55 of SIRA 2013 provides with power of the Labour Court and Tribunal to prohibit strike or lockout. Such power can only be exercised if strike or lockout is in existence and not to prevent apprehension strike and lock-out before it has commenced.  If a prima facie case is made out either by the CBA or the employer, and balance of convenience is in favour of the said claiming such order and irreparable loss and damage is to be caused due to threatened lock-out and strike, powers should be available both to Labour Court and the Tribunal to prohibit the threatened lock-out or strike, even before it is commenced, as also and apart to the right to prohibit a strike or lock-out once it has commenced.  Needless to mention that if such prohibition of lockout or strike is given by the Labour Court or the Tribunal, the demand shall be referred or adopted either by the Labour Court or the Tribunal to itself for adjudication.  Necessary incorporation in terms of Section 55 of SIRA 2013 in this behalf be effected.

Section 58 of SIRA 2013 deals with conditions of service to remain unchanged whilst proceedings are pending either before Conciliator, Arbitrator, Labour Court or Labour Appellate Tribunal.  It also provides for protection to office bearers during pendency of Conciliation or adjudication proceedings.  No time has been provided as to for what duration this protection will be available.  The whole provision is liable to be misused and grossly abused.  Even if permission is granted, which is almost rare and impossible, the aggrieved workmen can still challenge the dismissal all over again before the Court who will re-examine the matter as to the merits of dismissal.  No right of appeal against refusal to grant permission to dismiss is provided in law making the provision violation to law laid down by Apex Court, and the Shariah Amendments and modification of law is thus called for, and this anomaly in law be rectified and removed. 

Section 59 of SIRA 2013 provides that no employer shall remove any fixed assets of the establishment during the currency of an illegal lock-out or strike which is not illegal.  This provision of law is in direct conflict with the Article 18 of the Constitution of Pakistan which provides for  Freedom of Business and Trade conferred on employer.  Necessary amendment in the law to the aforesaid effect be therefore  incorporated in this Act.

Section 61 of the Act deals with representation of parties.  This provision of law as also more or less, identical provision under the earlier Industrial Relations legislation and has given a way out to those persons who are not enrolled Advocate and covered under Legal Practitioner and Bar Council Act 1973 to identify themselves as Labour Representatives and practice a profession of law.  It is recalled that Sindh Bar Council as early as 19.02.2011 had issued a Circular, details whereof are reproduced verbatim:-

“It has been observed that several persons (Ladies/Gents/Law Students etc.) who are neither Law Graduates nor enrolled with the Sindh Bar Council as advocate to practice in the Subordinate Courts and/or before High Court, illegally wear black coats/advocate’s uniform, posing themselves as advocate(s) before Sub-ordinate Court and/or Hon’ble High Court, such persons are surely not eligible to act/pose/practice as such and therefore are required to be strictly dealt with, hence, the Sindh Bar Council has taken serious notice of the fact and has decided that any person who is not enrolled as an Advocate except those under pupilage, if found in uniform of an Advocate or appear and/or imposes himself/herself in Courts as Advocate, strict legal action for impersonation in terms of section 58(1) of the Act, 1973 shall be taken immediately.  Further all the senior lawyers are requested to kindly make sure that the persons like those referred above, shall not appear before the Hon’ble High Court, if not enrolled as advocate(s) to act before the Hon’ble High Court and not before the Sub-ordinate Courts, if not enrolled by the Sindh Bar Council.

For ready reference, the relevant provision of Legal Practitioners & Bar Councils Act, 1973 is quoted below:

Section 58 (1) Act xxxv of 1973

Section 58 (1) any person who is not an advocate and practices the profession of law or any person who is not entitled under this Act to practice in the Supreme Court, a High Court or any other Court or Tribunal Subordinate thereto practices before the said Court or Tribunal shall be punished with Imprisonment for a term which may extend to three years, or with fine upto fifty thousand rupee, or with both.”;

It is therefore imperative that Section 61 of SIRA 2013 be appropriately redrafted by the legislature within the meaning and contemplation of Legal Practitioners and Bar Council’s Act 1973 as also within the circular and guidelines issued by the Sindh Bar Council.

Section 62 of the Act provides for interpretation of settlement and award to be given by the Labour Appellate Tribunal.  There can be a situation where difficulty and doubt as to the meaning of any of the provision of labour legislation may arise.  In order to avoid any labour unrest and in a legal and constitutional manner CBA and or the employer may prefer to obtain interpretation of any of the provision of law from the Labour Appellate Tribunal so that industrial peace and harmony continue to be maintained and there is no disruption in production.  It is therefore suggested that apart from interpretation of settlement and award, the sphere of power of the Sindh Labour Appellate Tribunal be extended to cover even interpretation of any of the provision of labour laws.  If an application is made either by the CBA or the employer requesting Labour Appellate Tribunal that difficulty and doubt has arisen as to the interpretation of any of the provision of labour legislation, the said reference be determined by the Tribunal who after giving the parties an opportunity of being heard shall decide the matter and its decision, subject to constitutional petition, being filed in the High Court should be treated as final and binding not only on employer, but on the CBA and in turn on all the workers of that establishment. 

Recovery of money due from an employer under a settlement or award is covered in terms of Section 63 of SIRA 2013.  It appears that legislature has failed to visualize, that just as an award is given by the Labour Court or the Labour Appellate Tribunal against the employer on the basis of industrial dispute raised by the CBA, much in the same way, an employer has also a right to raise industrial dispute against CBA and both Labour Court and Labour Appellate Tribunal can give an award against CBA.  The situation for recovery of money due by employer against CBA, in such an award can also arise.  It is therefore suggested that Section 63 of SIRA 2013 be amended as under:-

“Recovery of money due from and or by employer under any settlement or award: (i) any money due from or by employer under settlement or under an award or decision of the Arbitrator, Labour Court or Tribunal may be recovered as arrears of Land Revenue or as a public demand or the set off or adjusting from check-off amount or even from gratuity or provident fund of the workers, if upon an application of the person entitled to the money, Labour Court or the Tribunal so directs; (ii) where any workman or employer is entitled to receive from other side any benefit under a settlement or under an award or decision of the Arbitrator, Labour Court or the Tribunal, which is capable of being computed in terms of money, the amount at which such benefit shall be computed, may, subject to the rules made under this Act be determined and referred, as provided for in sub section (1) and paid to the workmen or the employer concerned within the specified date; (iii) Notwithstanding anything contained in any other law for the time being in force, legal dues of the workman or the employer as the case may be shall have priority in case of liquidation of the establishment or against any eligible payments due to the workmen; (iv) A Labour Court or the Labour Appellate Tribunal shall exercise the powers of collector under the Sindh Land Revenue Act 1962 (XVII of 1967) for recovery of an amount due under this Act.”

Section 64 of the Act provides for performance of functions pending ascertainment of CBA.  This provision is reproduction of Section 21 of the Industrial Relations Ordinance, 2011 corresponds almost verbatim to the earlier section 52 of the Industrial Relations Ordinance, 1969, and Section 22 of the Industrial Relations Ordinance, 2002 as also Section 71 of the Industrial Relations Ordinance, 2008. It is very unfortunate that framers of Industrial Relations Act 2013 have not yet realized that  this provision of law is invariably being  misused or abused  by large number of Unions through all these years.  The original section 52 of IRO, 1969 was introduced  as a stop gap arrangements as under prior law there was no concept of Collective Bargaining Agent but a Union  which was recognized by the employer could raise an industrial dispute.  The reasons for  Section 52 in IRO 1969,  find appearances in  all subsequent legislation although its need has ceased to exist, as invariably now  determination  of Collective Bargaining Agent has taken effect in all establishments.  There are large number of Unions who were last certified as CBA as early as 1972 who even now in 2014 after a lapse of more than 42 years continue to claim status of a CBA  on the ground that earlier they were so declared as CBA and were recognized by the employer.  This is redundant provision of law and should be deleted altogether being misused and abused, and or suitably amended to avoid undue misuse of law.

Section 65 to 71 provides for penalty for unfair labour practice, penalty for committing breach of settlement, penalty for failing to implement settlement, penalty for false statement, penalty for discharging office beakers of trade union in certain circumstances, penalty for embezzlement or misappropriation of union funds and penalty for other offence.  If industrial relations are to be developed and industrial peace and harmony is to be maintained, the concept of sending either employer or for that matter workers behind the Bar, or to sentence them to imprisonment be all discouraged.  No doubt ever settlement executed between CBA and the employer has to be implemented.  If willfully and deliberately employer fails to implement settlement, appropriate provision be incorporated in the SIRA 2013 whereby employer is called upon either by the Labour Court or Labour Appellate Tribunal to pay additional punitive cost over and above the amount involved.  This concept already exists in Section 35-A of CPC where courts are competent to impose costs which are either actual costs and or compensatory costs.  It is therefore suggested that above mentioned provision of law be suitably amended and necessary incorporation as to actual and compensatory costs to be imposed against employer or workers for breach or failure to implement settlement or award be incorporated, excluding thereby fine or imprisonment. So also embezzlement or misappropriation of union funds should be viewed seriously.  Union funds belong to the workers.  Office bearers of the union have neither any legal much less any moral right to embezzlement or misappropriation of these funds.  The law should appropriately be framed whereby if an office bearer of the union is found guilty of the embezzlement and misappropriation of union funds, the entire amount so embezzled or misappropriated be realized from the gratuity and or provident fund amount of the said worker office bearer of the union and on realization of such amount, it be reimbursed to the union in its account.  Presumption be raised that payment of the legal dues so realized have been made to the office bearers of the union and no further claim be entertained.  Appropriate amendment in law be thus made.

Section 73 of SIRA 2013 provides that where a person is guilty of an offence which is a company or other body corporate, then every Director, Manager, Secretary or other office or agent be deemed to be guilty of such offence.  This provision of law, with all respect and humility is liable to be misused and abused by disgruntled office bearers of the union.  Necessary amendments be therefore incorporated in the law whereby it be provided that for the purpose of holding liable, the employer may intimate to the CBA name of one person who would be held liable in case of any offence under the said Act.  Needless to mention intimation of one name in writing but to the government already exist in relation to those companies which are multinational companies.  More or less on the same pattern provision be incorporated and the law suitably be amended so that only one person so intimated by the employer or corporation to the government and to the CBA be held responsible in case of any offence allegedly committed under the said Act.

Section 78 of the Act provides for framing of the rules by the government for carrying out purpose of this Act.  It should be provided in law that framing of the rules be, not made in consultation with the government which is an executive but by the judiciary itself and rules namely Sindh Industrial Relations Rules 2014 be framed only in consultation with Chief Justice of High Court of Sindh.

Section 80 of SIRA 2013 deals with Repeal and Savings.  It is very unfortunate that this major provision of law has been drafted ignoring the very basic and elementary principle of law of interpretation.  IRA 2008 was a sunset provision as held by the Apex Court in the case of Air League reported in 2011 SCMR 1254.  This law expired on 30.04.2010.  This interpretation has been reiterated again by the Apex Court in Civil Appeal No. 1150.2012 in the case of State Bank of Pakistan, Civil Appeal No. 127.2013 in the case of Untied Bank Limited and C.P. No. 1754 and 1755 of 2012 in the case of SME Bank Limited, wherein Supreme Court of Pakistan have observed as under:-

“In the case of Air League PIAC Employees (Supra), this Court has held that Industrial Relations Act, 2012 stood repealed on the expiry of the period mentioned in Section 87(3) of the Act and consequence of such repeal will render the judgment of the Court corum non judice.  The Act stood repealed on 30.04.2010 and after that there was no legislation in the field of labour dispensation until 18.07.2011 when IRO 2011 was promulgated.”

It is very unfortunate the legislator in the Province of Sind in hot haste ignored these reported and unreported judgments of the Apex Court, and have in terms of Section 80 (i) repealed IRA 2008 in the year March 2013 when already this Act earlier stood repealed through sunset clause as early as 30.4.2010.  After the Eighteenth Amendment in the Constitution whereby Item No. 26 and 27 of the Concurrent List was deleted, it is only Provincial Government and not Federal Government that could frame labour legislation, except through invoking mandatory provision of Article 144 of the Constitution which provide that if one or more Provincial Assembly pass a resolution to the effect that Majlis-e-Shoora or the Parliament may by law regulate any matter not enunciated in the Federal Legislative List only in such a situation Majlis-e-Shoora can pass an Act.  Realizing this legal preposition Sindh Government after Eighteenth Amendment in the Constitution promulgated Industrial Relations (Revival & Amendment) Act 2010 and it was made effective as from 1st May, 2010.  Large number of trade unions were registered under this Act of 2010.  Settlements were concluded under this law.  Labour Court Judges were appointed under this law and even Labour Court and Labour Appellate Tribunal proceedings were filed under this provision of law some are still pending. For reasons best known, SIRA 2013 has only repealed IRA 2008 and has ignored to repeal the Sindh Industrial Relations (Revival & Amendment) Act 2010.  In due course of time, this will lead to litigation and industrial discontentment.  It is all to evident that popular Labour Law namely, SIRA 2013 was sought to be introduced by the outgoing Sindh Assembly on the eve of its dissolution without considering the consequences.  In view of 11-05-203 election, such labour legislation was framed and even passed in haste and not only government but the future government indeed, both labour and employer will suffer the consequences of such hasty framing of Section 80 of the Repeal and Saving clause.

Section 81 of the law provides that transfer of cases from NIRC to Sindh Labour Appellate Tribunal, Sindh Labour Court and the Registrar of Trade Unions Sindh having jurisdiction in the matter.  Large number of cases were entertained earlier under IRO 1969, IRO 2002, IRA 2008, IRO 2011 by the NIRC, even though it relates and pertains to establishment which are not trans-provincial in nature.  Constitution Petition challenging the right of the NIRC to entertain such cases were filed and even the decisions were given by the Courts but all in vain.  Now belatedly there is a realization on the part of the Government of Sindh to incorporate Section 81 in SIRA 2013, whereby it is provided that all cases pending in the NIRC acting as Registrar, Labour Court or as a Tribunal, all be transferred to the Registrar Province of Sindh, Labour Court in the Province of Sindh and Sindh Labour Appellate Tribunal having jurisdiction in the matter.  Already Labour Appellate Tribunal Sindh is over burdened with work is unable to cope with the work, there being almost more than 2000 cases pending in the Sindh Labour Appellate Tribunal at Karachi, with monthly institution of about 75 additional cases.  Transfer of cases from NIRC to the Labour Appellate Tribunal will add further pressure on Sindh Labour Appellate Tribunal making the plea of establishment of at least two Sindh Labour Appellate Tribunals duly presided over by the sitting Judge of the High Court all the more inevitable.  The plea is all the more genuine, and realistic and calls for early disposal of labour appeals and avoidance of labour unrest in the Province of Sindh.

Section 82 of SIRA 2013 provides that if there is any difficulty which has arisen to give effect to any provision of this Act, the Government of Sindh by notification in the official gazette can make such order which is not inconsistent with the approval of this Act, as may appear to be necessary for the purpose of removing difficulty.  Difficulty and doubt omission, inconsistencies and anomalies have already been mentioned herein above.  If Government of Sindh, now in power, is serious in the matter, let them examine these suggestions in larger national interest and remove these difficulties, inconsistencies and anomalies and doubts and invoke appropriate provision of law and or bring about amendments.

Ours is a world where people don’t know what they want and are willing to go through hell to get it.  We conclude wit Abraham Lincoln, American great President all famous quote:

“I am not bound to win, but I am bound to be true.  I am not to succeed, but I am bound to live by the light that I have.  I must stand with anybody that stand right, and stand with him while he is right, and part with him when he does wrong.”

Havelock Ellis has well said:

“What we call progress is the exchange of one nuisance for another naissance”.

Perhaps the learned Havelock Ellis has Labour Legislations passed in Sindh in mind.  Presently there is chaos in Sindh.  Henry Miller, an American author has said:

            “Chaos is the score upon which reality is written.”

Will our legislature listen and amend the law.  You can’t learn if you don’t make mistake.  It takes courage to stand up for what you believe in.

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