Supreme Court Reinstates Railway Employee After Withdrawal of Resignation: Key Legal Analysis

The case of S.D. Manohara vs. Konkan Railway Corporation Limited & Ors. is a landmark ruling on employee resignation withdrawal and reinstatement in public sector employment. The Supreme Court overturned the Karnataka High Court’s decision, ruling that the appellant had withdrawn his resignation before its acceptance, thereby entitling him to reinstatement.

This ruling emphasizes the importance of procedural fairness in handling resignations and reiterates the well-established legal principle that an employee has the right to withdraw their resignation before it is formally accepted by the employer.

Background of the Case

The appellant, S.D. Manohara, had been serving with the Konkan Railway Corporation Limited since 1990. After 13 years of service, he submitted his resignation on December 5, 2013, requesting that it take effect after one month.

However, he later decided to withdraw his resignation, which led to a legal dispute regarding whether his withdrawal was valid or if the resignation had already been accepted.

Key events in the case:

December 5, 2013: The appellant submitted his resignation, stating it should take effect after one month.
April 15, 2014: The employer internally recorded acceptance of the resignation, with effect from April 7, 2014.
May 10, 2014: The employer asked the appellant to report to duty, considering his unauthorized absence from April 28, 2014, to May 18, 2014.
May 19, 2014: The appellant reported to duty.
May 26, 2014: The appellant submitted a formal request to withdraw his resignation.
June 23, 2014: The employer rejected the request and relieved the appellant from service with effect from July 1, 2014.
2014: The appellant challenged the decision before the Karnataka High Court.
July 16, 2019: The Single Judge allowed the writ petition and directed reinstatement.
2021: The employer appealed to the Division Bench, which reversed the Single Judge’s ruling and upheld the rejection of the resignation withdrawal.
September 13, 2024: The Supreme Court set aside the Division Bench’s ruling, reinstating the appellant with partial back wages.

Legal Arguments

Arguments by the Appellant (S.D. Manohara)

The acceptance of resignation on April 15, 2014, was an internal communication and was never formally conveyed to him.
Since he had reported to duty on May 19, 2014, and was actively engaged in work, his resignation had not taken effect.
His withdrawal request on May 26, 2014, was within a reasonable timeframe and should have been accepted.
The employer’s action was arbitrary and violated principles of fairness and natural justice.

Arguments by the Respondents (Konkan Railway Corporation Limited)

The resignation was accepted with effect from April 7, 2014, and this decision was not open to challenge.
The appellant’s withdrawal request on May 26, 2014, was submitted after the resignation had already taken effect.
The company had taken procedural steps to process the resignation, including clearing dues and issuing formal relieving orders.
The Division Bench of the Karnataka High Court had correctly applied service law principles in dismissing the appellant’s claim.

Supreme Court’s Observations

1. Was the Resignation Accepted Before Withdrawal?

The Court noted that the letter of acceptance dated April 15, 2014, was an internal communication and was not formally conveyed to the appellant.

“The respondent-employer strongly relies on the letter of acceptance of resignation dated 15.04.2014 and submits that it has come into effect from 07.04.2014. We are inclined to accept the submission made by the appellant that the letter dated 15.04.2014 is an internal communication.”

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2. Continued Employment After Resignation

The Court emphasized that the employer had continued to engage with the appellant and had even directed him to report to duty on May 10, 2014, which indicated that the resignation had not been finalized.

“There is no reason as to why the respondent-Corporation would write a letter on 10.05.2014 requesting the appellant to report to duty for considering his unauthorized absence from 28.04.2014 to 18.05.2014.”

3. Application of Service Law Precedents

The Court reaffirmed the principle that an employee has the right to withdraw their resignation before it is formally accepted.

“Resignation can be withdrawn before its acceptance, is an established principle of law.”

Final Verdict

The Supreme Court issued the following directives:

The appeal was allowed, and the judgment of the Division Bench of the Karnataka High Court was set aside.
The appellant was ordered to be reinstated into service within 30 days from the date of the order.
The appellant was awarded 50% of the back wages for the period between July 1, 2014, and his reinstatement.
The service period from 2014 to reinstatement was to be counted for pensionary benefits.

This ruling reinforces the protection of employees against arbitrary employment decisions and ensures fairness in resignation and reinstatement cases.

Petitioner Name: S.D. Manohara.
Respondent Name: Konkan Railway Corporation Limited & Ors..
Judgment By: Justice Pamidighantam Sri Narasimha, Justice Pankaj Mithal.
Place Of Incident: Konkan Railway, India.
Judgment Date: 13-09-2024.

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