Go slowNot strikeSupreme Court of India

Crompton Greaves Ltd. v Workmen

(1978) 3 Supreme Court Cases 55819781 min read
The case in brief30-second read
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.
Issue
Whether go-slow constitutes a "strike" under S.2(q) of the Industrial Disputes Act
Held
Go-slow is NOT a strike because there is no "cessation of work"; work continues, only at a deliberately reduced pace.
Principle
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
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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

  1. Whether go-slow constitutes a "strike" under S.2(q) of the Industrial Disputes Act
  2. 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."

Exam use

How to use it in an answer

  • 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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Citation

Crompton Greaves Ltd. v. Workmen (1978) 3 Supreme Court Cases 558

Reported: SCC Online. This is an educational summary, not the judgment itself. Cite the reported version in professional or academic work.