Search Blog

Tuesday, May 28

An apprentice does not have a statutory right to claim an appointment

Haryana Power Generation Corporation Limited and Others vs. Harkesh Chand and Others, Civil Appeal No. 100 of 2013, (Arising out of S.L.P. (C) No. 29987 of 2010) Decided on January 7th, 2013


The Hon’ble Supreme Court held:

An apprentice does not have a statutory right to claim an appointment and the employer is not under any statutory obligation to give him employment. However, if the terms of the contract of apprenticeship lay down a condition that on successful completion of apprenticeship an employer would offer him an employment, then it is obligatory on his part to do so. In the absence of such a condition, there is no obligation. It depends on the terms of the contract”. [Para 27]

On the fact of the case the Court held:

In the case at hand, as the letter of appointment would show, the employer had only stated that on successful completion of the training, the apprentice may be appointed as Plant Attendant/Technician Grade-II. Thus, it was not a mandatory term incorporated in the agreement casting an obligation on the employer to appoint him”. [Para 27]

The Court noted following case law:

U.P. State Electricity Board v. Shiv Mohan Singh and Another  (2004) 8 SCC 402, A.K. Mathur, J., speaking for Hegde, J. and himself, while dealing with the status of apprentice, has stated: -

“Therefore a combined reading of the sections as well as Rules makes it clear that apprentices are only persons undergoing training and during that training they are entitled to get a particular stipend, they have to work for fixed hours and at the end of period of training they have to appear in the test and a certificate is issued to them. There is no obligation on the part of the employer to give them any employment whatsoever. The position of the apprentice remains as an apprentice trainee and during the period of training they will not be treated as workmen. Only obligation on the part of the employer is to impart them training as per provisions of the Act and Rules and to pay them stipend as required under Rule 11 and beyond that there is no obligation on the part of the employer to accept them as his employees and give them the status of workmen. There is no relation of master and servant or employer and employee.”

In the instant case the Court observed:

Be it noted, in the said case, in paragraph 51, it has been laid down that the 1961 Act is a complete code in itself and it lays down the conditions of the apprentices, their tenure, their terms and conditions and their obligations and what are the obligations of the employer. It also lays down that the apprentices are trainees and not workmen and if any dispute arises, then the settlement has to be made by the Apprenticeship Advisor as per Section 20 of the Apprentices Act, 1961 and his decision thereof is final. The nature and character of the apprentice is nothing but that of a trainee and he is supposed to enter into a contract and by virtue of that contract, he is to serve for a fixed period on a fixed stipend and that does not change the character of the apprentice to that of a workman under the employer where he is undergoing the apprenticeship training. Sub-section (4) of Section 4 only lays down that such contract should be registered with the Apprenticeship Adviser, but by non-registration of the contract, the position of the apprentice is not changed to that of a workman. From the scheme of the Act, the apprentice is recruited for the purpose of training as defined in Section 2(aa) of the Apprentices Act, 1961 and from the language employed in Sections 6 and 7, it is more than clear that the nature and character of the apprentice is that of a trainee only and on the expiry of the training, there is no corresponding obligation on the part of the employer to employ him”. [Para 23]


The Court also noted following case laws:

Narinder Kumar and Others v. The State of Punjab and Others, AIR 1985 SC 275 a two-Judge Bench dwelt upon the letter of appointment of apprentices and came to hold that the employer was bound to appoint the apprentices in the available vacancies because of Section 22(2) of the 1961 Act and the contractual obligations arising out of para 2 of the letter of appointment which stated that the apprentices shall be absorbed in the department if there are vacancies. Be it noted, emphasis was laid on the nature of the contract.

Dhampur Sugar Mills Ltd. v. Bhola Singh (2005) 2 SCC 470, while dealing with an award passed by the Labour Court under the U.P. Industrial Disputes Act relating to apprentices, a two-Judge Bench opined thus: -

“14. If the respondent was appointed in terms of the Apprentices Act, 1961, he will not be a workman, as has been held by this Court in Mukesh K. Tripathi v. Senior Divisional Manager, LIC (2004) 8 SCC 387 and U.P. SEB v. Shiv Mohan Singh (2004) 8 SCC 402.

15. In terms of the provisions of the Apprentices Act, 1961, a trainee or an apprentice has no right to be absorbed in services.”


To see full text follow the link: