Tribunal Cannot Grant Relief Beyond Terms of Reference | HC

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  • Last Updated on 10 December, 2025

tribunal award beyond terms of reference

Case Details: Eastern Coalfields Ltd. vs. Union of India [2025] 181 taxmann.com 143 (HC-Calcutta)

Judiciary and Counsel Details

  • Shampa Dutt (Paul), J.
  • Manik Das for the Petitioner.
  • Nandlal Singhania, Sr. Adv. for the Respondent.

Facts of the Case

In the instant case, the Respondent employee was working in the petitioner company. After his death, his son ‘A’ raised a dispute seeking compassionate employment in his father’s place.

The Appropriate Government referred the said dispute to the Tribunal for adjudication. The Tribunal dismissed the son’s claim but went on to hold that the wife of the deceased employee was entitled to monetary compensation from the date of the death of her husband till she attained 60 years of age.

The petitioner challenged the Tribunal’s order. It was noted that the Tribunal has jurisdiction to pass an award within the terms of reference, and it cannot go beyond those terms to pass an award.

High Court Held

The High Court held that since the Tribunal directed that the wife of the deceased employee was entitled to monetary compensation from management till she attained 60 years of age, such direction was beyond the terms of reference, as the same was not even incidental to the reference preferred.

Therefore, the direction given by the Tribunal to management to pay monetary compensation to the wife of the deceased employee was to be quashed.

List of Cases Referred to

  • Hochtief Gammon v. Industrial Tribunal, Bhubaneshwar, Orissa AIR 1964 SC 1746 (para 7).

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Taxmann Publications has a dedicated in-house Research & Editorial Team. This team consists of a team of Chartered Accountants, Company Secretaries, and Lawyers. This team works under the guidance and supervision of editor-in-chief Mr Rakesh Bhargava.

The Research and Editorial Team is responsible for developing reliable and accurate content for the readers. The team follows the six-sigma approach to achieve the benchmark of zero error in its publications and research platforms. The team ensures that the following publication guidelines are thoroughly followed while developing the content:

  • The statutory material is obtained only from the authorized and reliable sources
  • All the latest developments in the judicial and legislative fields are covered
  • Prepare the analytical write-ups on current, controversial, and important issues to help the readers to understand the concept and its implications
  • Every content published by Taxmann is complete, accurate and lucid
  • All evidence-based statements are supported with proper reference to Section, Circular No., Notification No. or citations
  • The golden rules of grammar, style and consistency are thoroughly followed
  • Font and size that's easy to read and remain consistent across all imprint and digital publications are applied