'Sleep & Work-Life Balance Necessary': Karnataka HC Sets Aside Suspension Of Constable Found Sleeping On Duty After Regular Double Shifts

Post By 24law
March 1, 2025

Pranav B Prem

In a significant ruling emphasizing the importance of work-life balance and adequate rest, the Karnataka High Court set aside the suspension of a constable employed with the Kalyan Karnataka Road Transport Corporation (KKRTC) who was found sleeping while on duty after consecutive double shifts. The Court held that depriving an employee of sleep could not be a ground for disciplinary action, especially when the employer itself had created the circumstances leading to exhaustion.

Background of the Case

The case arose when a vigilance report dated April 23, 2024, alleged that the petitioner, Chandrashekhar, a KKRTC constable, was found sleeping during his duty hours. A video of him sleeping was recorded and widely circulated on social media. Subsequently, the Corporation, contending that his actions had brought disrepute to the organization, placed him under suspension on July 1, 2024. However, the petitioner defended his case by stating that he had been assigned continuous double shifts—16 hours a day—for 60 consecutive days without a break. He also submitted that he had taken medication on medical advice and had only taken a brief power nap due to exhaustion. A report from the Vigilance Department confirmed that there were only three constables at the depot, leading to an excessive workload, and recommended hiring additional personnel to ease the burden on the existing staff.

Observations by the Court

Justice M. Nagaprasanna, while delivering the judgment, highlighted the necessity of sleep and a balanced work-life structure for employees, remarking: "It is trite, if a person is asked to overwork than his capacity, the body sometimes makes the said person to sleep, as sleep and work life balance is what is necessary today."

The Court observed that the petitioner was compelled to work for 16 hours daily for 60 consecutive days and that such prolonged work conditions inevitably resulted in exhaustion. Referring to Article 24 of the Universal Declaration of Human Rights, which states that “everyone has the right to rest and leisure, including reasonable limitation of working hours and periodic holidays with pay,” the Court stressed on the fundamental right to rest and leisure for employees. Additionally, the Court referenced international labor standards, stating: "The covenants in the International Labour Organization to which the Nation is a part, recognizes the work and life balance. The hours of work should not exceed 48 hours in a week and 8 hours in a day, except in exceptional circumstances, is what is indicated."

The judgment also cited precedents from the High Courts of Calcutta and Uttarakhand, reaffirming the right to sleep and work-life balance. The Calcutta High Court, in Birangana Religious Society v. State and Burrabazar, Fire Works Dealers Assn. v. Commissioner of Police, Calcutta, had acknowledged the right to sleep as fundamental, stating: "Under our Constitution, people has a right to sleep and leisure. Disruption or disturbance in sleeps creates mental stress, deficient in working efficiency and other things." The Uttarakhand High Court in Arun Kumar Bhadoria v. State also stressed the necessity of humane working conditions for employees in organizations, particularly law enforcement and security personnel.

Court's Verdict

Taking into account the excessive working hours imposed on the petitioner, the Court held that there was no misconduct in the peculiar facts of the case: "Employees in any organization much less, who are working on shifts must have work and life balance. Therefore, no fault can be found with the petitioner sleeping in duty hours, in the peculiar facts of the case."

Further, the Court clarified that if the petitioner had been sleeping on duty while working a single shift, it would have constituted misconduct. However, considering that he had been forced to work 16-hour shifts without breaks, the disciplinary action taken against him was unjustified. The Court ruled: "In the case at hand, the petitioner is made to over work by two shifts of 16 hours, in 24 hours, for 60 long days without break. Therefore, the action of the respondent placing the petitioner under suspension for the folly of the respondent, is undoubtedly an action which suffers from want of bonafides, the order is thus rendered unsustainable and is to be obliterated." Accordingly, the High Court allowed the petition, quashing the suspension order and directing the Corporation to reinstate the petitioner with all consequential benefits, including salary for the suspension period.