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Madras High Court· 25 September 2026

Is Section 4(1)(c) of the Tamil Nadu Shops and Establishments Act, 1947 of no consequence to the Tamil Nadu Industrial Establishments (Conferment of Permanent Status to Workmen) Act, 1981, which incorporated only the definition of establishment?

The District Manager v. The Assistant Commissioner of Labour (Enforcement)
WA(MD).2017/2025 · 2026:MHC:3941 · W.A.(MD)No.2017 of 2025
Coram: Justice C.V. Karthikeyan · Justice R.Sakthivel
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Answer

Section 4(1)(c) of the Shops Act is of no consequence to the Permanent Status Act, which incorporated only the definition of establishment.

Yes. Section 4(1)(c) of the Shops Act is of no consequence to the Permanent Status Act, which incorporated only the definition of establishment. Following the Division Bench in V. Elayaperumal v. State Bank of India, the Court held that the definition of establishment is lifted from the Shops Act into the Permanent Status Act, but the exemption for establishments under the Central and State Governments is not, and the Permanent Status Act continues to apply to such establishments unless exemption has been obtained from the State Government under Section 9. The argument that every other provision of the Shops Act travels with the borrowed definition was rejected.

Headnote

Tamil Nadu Industrial Establishments (Conferment of Permanent Status to Workmen) Act, 1981 — Ss.2(3)(e), 3, 9 — Tamil Nadu Shops and Establishments Act, 1947 — Ss.2(6), 4(1)(c) — Conferment of permanent status — TASMAC salesmen — Exemption of Government establishments — Letter of the Principal Secretary — Closure of shops — Permanent Status Act, 1981 — S.9 — Exemption — Letter of the Principal Secretary to the Government — Held: A letter of the Principal Secretary to the Government opining that no exemption is required is at most a private opinion of its author; it is not the law of the land, does not bind the Court and is not a notification granting exemption. When the law directs a particular act to be performed in a particular manner, it must be done only in that manner. (¶27, 34) Shops and Establishments Act, 1947 — S.4(1)(c) — Incorporation by reference — Definition of establishment — Held further: Only the definition of establishment is incorporated from the Shops Act into the Permanent Status Act, so the exemption in s.4(1)(c) of the Shops Act is of no consequence, and the Permanent Status Act continues to apply unless exemption is obtained from the State Government under s.9. V. Elayaperumal v. State Bank of India, 2007 (2) LLN 212, followed. (¶35, 36) Permanent Status Act, 1981 — S.3 — 480 days of continuous service — Closure of shops — Held further: A workman with 480 days of continuous service within 24 consecutive months must automatically be made a permanent employee; mere closure of shops does not imply that the tenure of workmen accommodated in other shops stood terminated. Writ appeals dismissed. (¶28, 37, 40, 43)

Headnote

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In the Court's own words
Paragraph 31He therefore expanded his argument by stating that every other provision under the Shops Act should also be automatically incorporated, even though not specified by the Legislation to the Permanent Status Act and therefore, argued that Section 4(1)(c) of the Shops Act would also be attracted to the Permanent Status Act.
Paragraph 35We would on the other hand place reliance on a judgment of this Court reported in 2007 (2) L.L.N. 212, in the case of V.Elayaperumal and others -vs.- State Bank of India and others, which in our opinion, has laid down the correct position of law and with the pronouncement which we respectfully and with much pleasure follow. The position of law had been very succinctly put by the Division Bench in paragraph No.17, which is as follows:
Paragraph 36This dictum very clearly establishes that not only is Section 4(1)(c) of the Shops Act of no consequence but also that the Permanent Status would continue to apply and in effect, re-enforces our opinion that the letter of Principal Secretary is also of no consequence.
Acts & Sections
Section 3 Tamil Nadu Industrial Establishments (Conferment of Permanent Status to Workmen) Act, 1981Section 9 Tamil Nadu Industrial Establishments (Conferment of Permanent Status to Workmen) Act, 1981Section 2(6) Tamil Nadu Shops and Establishments Act, 1947Section 4(1)(c) Tamil Nadu Shops and Establishments Act, 1947

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Also decided in this judgment
Is a letter of the Principal Secretary to the Government a notification granting exemption under Section 9 of the Tamil Nadu Industrial Establishments (Conferment of Permanent Status to Workmen) Act, 1981?Must a workman with 480 days of continuous service within 24 consecutive months automatically be made a permanent employee under the Tamil Nadu Industrial Establishments (Conferment of Permanent Status to Workmen) Act, 1981?Does mere closure of shops imply that the tenure of workmen accommodated in other shops stood terminated under the Tamil Nadu Industrial Establishments (Conferment of Permanent Status to Workmen) Act, 1981?
Plain-language answer prepared by the LexStreak Editorial Desk — verify against the judgment. Source: Madras High Court. Corrections