With the help of decided cases decide whether the following persons are workmen under Industrial Dispute Act, 1947: (i) A Temple Priest (ii) An engineer of XYZ Ltd. (iii) Head Constable of Delhi Police (iv) Development o

(i) A Temple Priest : A priest is not a workmen under the provisions of section 2(s) of the Industrial dispute Act. The function of the priest cannot " be equated with a mere wage earner and his services cannot be treated as manual or clerical etc. as held in the case of Kesava Bhatt vs. Shree Ambulam Trust (1990) Lab LJ 192 (Ker) . (ii) Engineer of XYZ Ltd. : A person doing technical work is also held as a workmen. A work which depends upon the special training or scientific or technical knowledge of a person is a technical work. Once a person is employed for his technical qualifications, he will be held as a workmen under the provisions of Industrial Dispute Act. (iii) Head Constable of Delhi Police : The Head Constable of Delhi police is not a workman under the Industrial Dispute Act, 1947 as he is performing the sovereign function, further the function of Delhi Police cannot be an Industry under any circumstance. The main function of the Delhi police is to maintain law and order which is a sovereign function. (Exception (ii) of section 2(s) of ID Act, 1947). (iv) Development officer of LIC : A Development officer of LIC was held to be a workman. Keeping in view the nature of duties performed by such officers and the powers vested in them they cannot be said to be engaged in any administrative or managerial work. Designation and name of the post is not a decisive factor. It was found that a Development officer has no subordinate staff working under him, he is generally placed on par with subordinate and clerical staff. ( Standard Vacuum Oil Co. vs. Commissioner of labour ).