Crompton Greaves Ltd. v. Workmen
Rule established
Go-slow is NOT a strike (no cessation of work) but IS serious misconduct: more insidious than strike because workers receive full wages while deliberately reducing output
Facts
- Workers at Crompton Greaves engaged in "go-slow": deliberately reducing work pace without actually stopping work
- Production fell significantly while workers continued receiving full wages
- Employer treated go-slow as misconduct and took disciplinary action
- Workers argued go-slow was a form of strike protected under industrial disputes law
Issues
- Whether go-slow constitutes a "strike" under S.2(q) of the Industrial Disputes Act
- Whether employer can take disciplinary action for go-slow
Held
- Go-slow is NOT a strike because there is no "cessation of work"; work continues, only at a deliberately reduced pace
- Go-slow is a SERIOUS FORM OF MISCONDUCT, more insidious than a strike because:
- During a strike, the employer can take counter-measures (lockout, replacement workers)
- During go-slow, the employer is helpless: paying full wages for fraction of output
- Workers cannot claim any strike-related immunities or protections
Ratio Decidendi
"Go-slow is a serious type of misconduct as it involves deliberate reduction in output without any justification. It is more harmful than strike because during strike the employer can take countermeasures, but during go-slow he is helpless while paying full wages for reduced work."
How to use it in an exam
- Part A: "Is go-slow a strike? No. Crompton Greaves (1978): go-slow = no cessation = not strike. But IS serious misconduct justifying dismissal."
- Part B/C: Critical for any problem where workers reduce output without stopping. Employer CAN take disciplinary action. Workers CANNOT claim strike immunities (S.17-18 don't apply).
- Key line: "Go-slow is more insidious than strike because the employer is helpless while paying full wages for reduced work."
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Source
Source: SCC Online
This is an educational summary, not the judgment itself. Cite the reported version in professional or academic work.