Source:  Karnataka High Court 

Why in News? 

Recently, the bench of Justice M Nagaprasanna has overturned suspension of a Kalyan Karnataka Road Transport constable penalized for sleeping on duty. 

• The Karnataka High Court held in the matter of Sri. Chandrashekhar v. The Divisional Controller (2025). 

What was the Background of Sri. Chandrashekhar v. The Divisional Controller Case? 

• Chandrashekhar, a Karnataka State Transport (KST) constable appointed on 13th May 2016, was transferred to work at the Kalyan Karnataka Road Transport Corporation due to shortage of staff. 
• On 23rd April 2024, a vigilance report alleged that Chandrashekhar was found sleeping while on duty, which was video recorded and circulated on social media platforms. 
• When questioned, Chandrashekhar stated that he had taken medicine as per doctor's advice and had taken a power nap of ten minutes as he was on continuous duty in second and third shifts. 
• The Vigilance Department submitted a report stating that there were only three KST constables in the depot, the workload on existing staff was extremely high, and suggested appointing two more constables. 
• Despite the Vigilance Department's findings regarding staff shortage, Chandrashekhar was placed under suspension on 01st July 2024 for sleeping on duty. 
• The Corporation contended that Chandrashekhar's act of sleeping while on duty, which was video recorded and circulated on social media, brought disrepute to the Corporation. 
• It was an admitted fact that Chandrashekhar was made to work double shifts of 16 hours per day continuously for approximately 60 days without break due to staff shortage. 
• Chandrashekhar filed a writ petition before the Karnataka High Court challenging the suspension order and seeking reinstatement to his previous post.

What were the Court’s Observations?

• The Court observed that if a person is asked to work beyond their capacity, the body sometimes compels the person to sleep, as sleep and work-life balance are necessary in contemporary times. 
• Referring to Article 24 of the Universal Declaration of Human Rights, the Court emphasized that everyone has the right to rest and leisure, including reasonable limitation of working hours and periodic holidays with pay. 
• The Court noted that the covenants in the International Labour Organization, to which India is a signatory, recognize work-life balance and stipulate that working hours should not exceed 48 hours in a week and 8 hours in a day, except in exceptional circumstances. 
• The Court observed that while sleeping on duty during a single shift would undoubtedly constitute misconduct, no fault could be found with the petitioner sleeping during duty hours in the peculiar facts of this case. 
• The Court held that employees in any organization, particularly those working on shifts, must have work-life balance, and placing the petitioner under suspension for the respondent's own folly demonstrated a lack of bonafides. 
• The Court determined that the suspension order was unsustainable and deserved to be set aside, with the petitioner entitled to all consequential benefits including continuity of service and salary for the suspension period. 

Does Sleeping on Duty Constitute Misconduct?  

• Right to rest and leisure as recognized in Article 24 of the Universal Declaration of Human Rights (UDHR) , which includes reasonable limitation of working hours and periodic holidays with pay. 
• International Labour Organization covenants that establish standards for work hours (not exceeding 48 hours weekly and 8 hours daily except in exceptional circumstances). 
• The distinction between misconduct (sleeping during a regular single shift) versus excusable behavior (sleeping when forced to work excessive hours over prolonged periods). 
• The principle of work-life balance as a necessary element for employees, particularly those working in shift-based roles. 
• The concept of "bonafides" in administrative actions, suggesting that employer actions must be undertaken in good faith, particularly when disciplining employees. 
• The legal authority of the court to quash suspension orders that lack reasonable basis or demonstrate arbitrary exercise of power. 
• The principle of consequential benefits following the quashing of an improper suspension, including continuity of service and back wages for the suspension period 

What is Article 24 of UDHR? 

• The Court specifically referenced Article 24 of the Universal Declaration of Human Rights, which states: "Everyone has the right to rest and leisure, including reasonable limitation of working hours and periodic holidays with pay." 
• This provision establishes several legal principles: 
  • The universal right to rest and leisure as a fundamental human right 
  • The necessity of reasonable limitations on working hours as an essential component of this right 
  • The requirement for periodic holidays with pay as part of ensuring this right 
• The Court used this international human rights standard as a foundational basis for its reasoning that excessive work hours (16 hours daily for 60 continuous days) violated the petitioner's basic rights.  
• The Court states that this right is not merely aspirational but has practical implications for employment practices and workplace regulations, particularly when determining what constitutes reasonable grounds for disciplinary action.