"Depriving Sleep To Any Human Being, Will Lead Falling Sleep Anywhere": Karnataka High Court Quashes Suspension Of Constable Found Sleeping On Duty
"It is trite, if a person is asked to over work than his capacity, the body sometimes makes the said person to sleep, as sleep and work-life balance is what is necessary today," the High Court observed.
The Karnataka High Court has set aside the suspension of a constable employed with the Kalyan Karnataka Road Transport Corporation (KKRTC), imposed on the grounds that he was found sleeping while on duty.
The Single Bench of Justice M. Nagaprasanna underscored the importance of sleep and work-life balance, emphasizing that depriving employees of adequate rest could have adverse consequences.
"It is trite, if a person is asked to over work 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.
Advocates Ravi Hegde and Vinay Kumar Bhat appeared for the Petitioner, while Advocate Prashant S. Hosamani appeared for the Respondent.
Court's Observations on Work-Life Balance
The Court noted that an excessive workload had forced the petitioner, Chandrashekhar, to work extended shifts without sufficient rest.
The Court further observed, “It may be a constable today, tomorrow it can be anybody. Depriving sleep to any human being will lead to falling asleep anywhere. Therefore, sleep and leisure are considered an important facet of the balance that is to be struck between work and life.”
Case Background
On April 23, 2024, a vigilance report alleged that the petitioner was found sleeping while on duty. A video of the incident was recorded and circulated on social media, leading to disciplinary action. Following the video’s circulation, the vigilance department obtained a statement from the petitioner regarding the reason for his conduct.
The vigilance department also submitted a report noting that there were only three KST constables deployed in the depot, leading to an extremely high workload. The report recommended appointing two additional constables to alleviate the burden on existing staff.
In his defense, Chandrashekhar stated that he had been following medical advice and taking prescribed medication. He further explained that he had been working continuous shifts, including second and third shifts, which led to his taking a brief power nap of ten minutes.
However, the corporation maintained that the petitioner had been caught sleeping on duty and that the circulation of the video had brought disrepute to the organization, justifying his suspension.
Court’s Findings
The Court took into account the heavy workload borne by the petitioner. It noted that the standard duty of a KST constable in the corporation is eight hours per shift. However, due to staff shortages, the petitioner had been working two consecutive shifts—totaling 16 hours per day—for 60 consecutive days.
Referring to Article 24 of the Universal Declaration of Human Rights, which recognizes the right to rest and leisure, including reasonable working hours and periodic holidays, the Court emphasized that international labor standards advocate a maximum work schedule of 48 hours per week and 8 hours per day, except in exceptional circumstances.
The Court held, “Employees in any organization, much less those working in shifts, must have work-life balance. Therefore, no fault can be found with the petitioner sleeping during duty hours in the peculiar facts of the case.” It further clarified that had the petitioner slept during a standard single shift, it would have been deemed misconduct.
Court’s Verdict
Allowing the petition, the Court ruled, “In the case at hand, the petitioner was made to overwork by two shifts of 16 hours, within 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 Court allowed the Writ Petition and ordered, "The order of suspension dated 01.07.2024, passed by the respondent is hereby quashed.The petitioner is entitled to all consequential benefits, including continuity of service and salary, for the period that he was placed under suspension."
Cause Title: Shri Chandrashekhar v. The Divisional Controller [Neutral Citation No. 2025:KHC-D:1089]
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