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Jyoti Kumar vs M/S Zydus Healthcare Ltd on 21 January, 2026 cites

Novartis India Limited vs Vipin Shrivastava on 20 December, 2016

In the case of Novertis India Ltd Vs Vipin Shrivastava 2018 SCC Online MP 1931 , a Division Bench held that in the German Remedies Limited's case (supra), has misread the judgment in H.R. Adyanthaya's case (supra) to hold that Medical Representatives are workmen within the meaning of Section 2(s) of the ID Act. In fact, three categories were created by the Supreme Court. In respect of the Medical Representatives engaged prior to enactment of SPE Act w.e.f. 06.03.1976, they were held not governed either by ID Act or SPE Act. In respect of employees whose services were terminated after 06.03.1976, the appeals were dismissed for the reason that it is not the case of the employees that their wages were less than Rs.750/- per month excluding commission, therefore, the SPE Act did not apply to them. The only dispute which was referred to Industrial Court under the Maharashtra Recognition of Trade Unions and Prevention of Unfair Labour Practice Act, 1971 was in respect of transfer of the employees affected on 16.02.1988. The Supreme Court found that the definition of workman under ID Signature Not Verified Signed by: SOURABH YADAV Signing time: 24-01-2026 16:01:24 NEUTRAL CITATION NO. 2026:MPHC-IND:1897 12 WA-3155-2025 Act will not cover the sales promotion employees within the meaning of SPE Act.
Madhya Pradesh High Court Cites 23 - Cited by 20 - S Yadav - Full Document

H.R. Adyanthaya vs Sandoz (India) Ltd on 11 August, 1994

He further submits that the Apex Court has placed reliance on a case reported in 1994 (5) SCC 737 parties being [H.R. Adyanthaya Vs. Sandoz (India) Ltd.] and therefore, the order passed by the Division Bench in the case of Novartis India Limited (supra) also placing reliance in the case of Adyanthaya (supra) has held that the Medical Representative does Signature Not Verified Signed by: SOURABH YADAV Signing time: 24-01-2026 16:01:24 NEUTRAL CITATION NO. 2026:MPHC-IND:1897 14 WA-3155-2025 not fall within the definition of workman.
Supreme Court of India Cites 37 - Cited by 142 - K Singh - Full Document

Ripu Daman Bhanot vs The Presiding Officer, Labour Court And ... on 12 August, 1996

15. The aforesaid judgment passed by the Apex Court had also been considered by the Rajasthan High Court in Dolphin Laboratories Ltd. v. Judge, Labour Court, Udaipur and Another 2001-II-LLJ-559 (Raj.) and also by Punjab & Haryana High Court in Ripu Daman Bhanot v. Presiding Officer, Labour Court, Ludhiana and Ors. 1997-I-LLJ-557 (P&H). The aforesaid two High Courts have also dealt with the similar questions and relying upon the ratio of Sandoz's case (supra) held that Medical Representative is a workman for the purpose of Section 2(s) of the Industrial Disputes Act, 1947.
Punjab-Haryana High Court Cites 20 - Cited by 13 - M L Singhal - Full Document
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