Recent Legal Developments
The Karnataka High Court recently overturned the suspension of a Kalyan Karnataka Road Transport constable who was penalized for sleeping on duty. The case, Sri Chandrashekhar v. The Divisional Controller (2025), was heard by a bench led by Justice M. Nagaprasanna.
Background of the Case
Sri Chandrashekhar, a Karnataka State Transport (KST) constable, was appointed on May 13, 2016. Due to a shortage of staff, he was transferred to the Kalyan Karnataka Road Transport Corporation.
On April 23, 2024, a vigilance report alleged that Chandrashekhar was found sleeping during his duty. A video of the incident was recorded and circulated on social media. When questioned, he explained that he had taken medication as prescribed by a doctor and took a brief ten-minute power nap after working continuous second and third shifts.
The Vigilance Department, acknowledging the severe staff shortage, recommended the appointment of two additional constables. However, despite this recommendation, Chandrashekhar was suspended on July 1, 2024, for sleeping while on duty. The Corporation argued that his actions had brought disrepute to the organization.
Chandrashekhar challenged his suspension before the Karnataka High Court, seeking reinstatement and back pay.
Court’s Observations
The Karnataka High Court emphasized that excessive work hours could compel an individual to sleep involuntarily.
The key observations were:
Sleep and work-life balance are essential in modern work environments.
Article 24 of the Universal Declaration of Human Rights (UDHR) affirms the right to rest and leisure, including reasonable limitations on working hours and periodic paid holidays.
International Labour Organization (ILO) standards state that working hours should not exceed 48 hours per week and 8 hours per day, except under exceptional circumstances.
While sleeping during a regular shift may constitute misconduct, the facts of this case demonstrated an exception. The constable had been forced to work 16-hour shifts continuously for 60 days due to a staff shortage.
The Court held that suspending Chandrashekhar for the employer's failure to ensure proper staffing lacked bona fides.
The suspension order was set aside, and Chandrashekhar was entitled to all consequential benefits, including continuity of service and back wages for the suspension period.
Does Sleeping on Duty Always Violate Work-Life Balance?
The Court drew a distinction between:
Misconduct: Sleeping during regular working hours without justification.
Excusable Behavior: Sleeping due to prolonged overwork and excessive shifts.
The ruling reaffirmed that employers must act in good faith when taking disciplinary measures. Arbitrary punishments, particularly in cases of extreme workloads, may not stand up to judicial scrutiny.
Significance of Article 24 of the UDHR
The Court referenced Article 24 of the UDHR, which states:
"Everyone has the right to rest and leisure, including reasonable limitation of working hours and periodic holidays with pay."
This provision underscores the fundamental human right to:
Rest and leisure as a universal necessity.
Reasonable limitations on working hours to prevent exploitation.
Paid holidays as part of a balanced work environment.
The Court’s ruling reinforced that these principles have practical implications in employment law, ensuring that excessive work hours do not infringe upon fundamental rights.
Conclusion
The Karnataka High Court’s decision in Sri Chandrashekhar v. The Divisional Controller highlights the importance of work-life balance and employee rights. The judgment sets a precedent that excessive work hours and employer negligence in staffing cannot justify punitive actions against employees. It serves as a reminder that legal protections exist to uphold workers' rights to fair working conditions.
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