Legal Review and Analysis of Konkan Railway Corporation Ltd & Ors vs S D Manohara 2025 INSC 1368

Case Synopsis

Konkan Railway Corporation Ltd. & Ors. vs S.D. Manohara

Citation: 2025 INSC 1368

Synopsis Headline: Equity Prevails: Supreme Court Upholds Employee's Right, Dismisses Review on Technicalities

Synopsis: The Supreme Court dismissed a review petition filed by Konkan Railway, affirming its prior judgment that allowed an employee to withdraw his resignation before its formal acceptance. The Court held that substantive justice and equity, considering the employee's 23 years of unblemished service, outweighed technical arguments about internal correspondence. It also upheld the award of 50% back wages as a balanced equitable relief. The order reinforces that a resignation can be withdrawn prior to acceptance and underscores the Court's discretion to mould relief based on fairness in service jurisprudence.

Legal Review and Analysis of   Konkan Railway Corporation Ltd. & Ors. vs S.D. Manohara

1. Bench Details and Case Citation

Case Title: Konkan Railway Corporation Ltd. & Ors. vs S.D. Manohara
Citation: 2025 INSC 1368
Court: Supreme Court of India
Jurisdiction: Inherent Jurisdiction (Review Petition)
Coram: Justice Pamidighantam Sri Narasimha and Justice Pankaj Mithal
Date of Order: November 25, 2025

2. Relevant Legal Principles

While the order does not cite specific statutes, it interprets and applies foundational principles of service law and natural justice:

• Principle of Effective Resignation: A resignation becomes effective only upon its acceptance by the employer. An employee has the right to withdraw the resignation before such acceptance.

• Equity and Justice in Service Matters: Courts can intervene to prevent injustice, especially considering an employee's long and unblemished service record.

• The "No Work, No Pay" Principle: An employee is generally not entitled to wages for a period they did not render service.

• Scope of Review Jurisdiction: A review petition is not an appeal. It can only be entertained to correct an "error apparent on the face of the record," not to re-argue the case on merits.

3. Judgment Analysis: Facts, Issues, and Reasoning

A. Factual Matrix

The respondent, S.D. Manohara, was an employee of Konkan Railway Corporation Ltd. He submitted his resignation on December 5, 2013, to be effective from January 5, 2014. Subsequently, on May 26, 2014, he withdrew his resignation. The employer, however, issued letters/orders on June 23, July 1, and July 15, 2014, stating that his resignation was accepted and he was relieved from service with effect from July 1, 2014. The employee challenged this, arguing that his withdrawal preceded the acceptance. The Supreme Court, in its original judgment dated September 13, 2024, allowed the employee's appeal, holding that the withdrawal was valid and directing his reinstatement with 50% back wages for the period he was out of service. The employer filed this review petition against that judgment.

B. Core Legal Issues Addressed

The Supreme Court, in this review petition, addressed the following issues:

1. Whether there was an "error apparent on the face of the record" in the original judgment warranting its review, specifically regarding the timing of the resignation's acceptance.

2. Whether the award of 50% back wages was contrary to the principle of 'no work, no pay'.

C. Ratio Decidendi: The Court's Reasoning and Core Principles

The Supreme Court dismissed the review petition, upholding its original judgment. The Court's reasoning was grounded in substantive justice and a holistic view of the facts.

• Timeline Establishes Right to Withdraw: The Court reaffirmed that the crucial fact was the sequence of events. The employee's withdrawal on May 26, 2014, came before the conclusive acceptance evidenced by the employer's own communications dated June 23 and July 1, 2014. Therefore, as a matter of law, the resignation stood withdrawn before it could be accepted, making the subsequent acceptance invalid.

• Substance Over Form in Correspondence: The petitioner argued that an internal letter dated April 15, 2014, constituted acceptance. The Court rejected this technicality, focusing on the final and conclusive communications that clearly established July 1, 2014, as the effective date of acceptance. The Court emphasized that justice could not be decided on the basis of "contentious correspondence" but on the definitive position taken by the employer.

• Equity and Long Service Trump Technicalities: The Court invoked principles of equity and justice. It gave significant weight to the employee's 23 years of unblemished service. In this context, the Court held it would be unjust to sever the employment relationship by interpreting a few letters, especially when the employee had been litigating to retain his job for over a decade. This highlights the Court's role in preventing harsh outcomes based on procedural technicalities.

• 50% Back Wages: A Balanced Equitable Relief: The Court addressed the 'no work, no pay' principle. It agreed that full back wages may not be warranted. However, awarding 50% back wages was a balanced equitable measure to do substantial justice, considering the employer's role in the protracted dispute and the employee's long service. This was not a violation of the principle but a calibrated application of equity to mitigate the hardship caused by the illegal termination.

• Review Jurisdiction is Limited: The Court implicitly affirmed the narrow scope of review. The errors pointed out by the petitioner pertained to a re-appreciation of facts and did not constitute a patent legal error apparent on the face of the record. A review petition cannot be used to re-hear the case on merits.

4. Final Outcome and Directions

The Supreme Court dismissed the review petition.

• The original judgment dated September 13, 2024, was upheld.

• The respondent-employee's reinstatement was confirmed.

• The direction for payment of 50% back wages from July 1, 2014, till reinstatement was also confirmed.

• Each party was to bear its own costs.

MCQs Based on the Judgment

1. In Konkan Railway Corporation Ltd. vs S.D. Manohara (2025 INSC 1368), the Supreme Court upheld the employee's right to withdraw his resignation primarily because?
(a) The employee had rendered 23 years of unblemished service.
(b) The withdrawal letter was submitted before the resignation was conclusively accepted by the employer.
(c) The employer failed to follow its internal HR procedures.
(d) The principle of 'no work, no pay' was not applicable.

2. The Supreme Court justified granting 50% back wages to the reinstated employee by?
(a) Strictly applying the 'no work, no pay' principle.
(b) Holding the employer solely liable for the entire period of unemployment.
(c) Exercising equitable jurisdiction to balance justice between the parties.
(d) Punishing the employer for malicious intent.