High Court brings airline pilots under labour law protection, rejects managerial classification

In a significant ruling with implications for the aviation industry, the High Court has held that airline pilots, including pilots-in-command, fall within the definition of “workmen” under the Industrial Disputes Act, affirming that their core role is technical and operational rather than managerial or supervisory.

The judgment was delivered by a Division Bench comprising Justice Anil Kshetarpal and Justice Harish Vaidyanathan Shankar while hearing a batch of Letters Patent Appeals filed by King Airways. The airline had challenged earlier orders directing it to clear unpaid salaries, incentives for additional flying hours and other dues owed to several former pilots, including Captain Pritam Singh, Manjit Singh and N D Kathuria.

Also read: DGCA flags operational gaps at IndiGo; senior executive under regulatory scrutiny

At the heart of the ruling, the Bench applied the long-established “predominant nature of duties” test to determine whether pilots qualify as workmen under the Industrial Disputes Act. The Court observed that while a pilot-in-command has authority over an aircraft during flight operations, this command does not translate into supervisory or managerial control in an industrial or administrative context.

The judges noted that the principal responsibility of pilots is the skilled and technical operation of aircraft. There was no material on record to show that pilots exercised decision-making powers over employment conditions, disciplinary control or organisational management of crew members.

Also read: Centre weighs interest-free AGR moratorium for Vodafone Idea; dues reassessment may halve payout

The Court rejected the airline’s argument that pilots should be excluded from labour law protections on account of their seniority or higher pay. It clarified that the salary ceiling under the Industrial Disputes Act becomes relevant only after it is established that an employee performs supervisory functions. In the absence of such a finding, exclusion under Section 2(s)(iv) of the Act cannot be invoked.

The Bench also dismissed King Airways’ reliance on provisions of the Aircraft Rules and internal operational manuals to contend that pilots supervise cabin crew. It held that any authority exercised by pilots under aviation regulations is incidental to ensuring flight safety and operational discipline, and cannot be equated with managerial or supervisory control as understood under labour laws.

The ruling reinforces the position that professional qualifications, designations or high remuneration alone do not determine an employee’s status under the Industrial Disputes Act. Instead, courts must assess the actual nature of duties performed, a principle that could influence future disputes involving highly skilled professionals across sectors.