The Karnataka High Court has overturned a suspension verdict against a Kalyan Karnataka Road Transport Corporation constable who was discovered to be dozing off while on duty.

When granting Chandrashekhar's petition, Justice M. Nagaprasanna emphasized the importance of adequate sleep and work-life balance for workers. According to the statement, "It is trite, if a person is asked to work harder than he can, the body sometimes forces him to sleep, as sleep and work-life balance is necessary today."

"It could be a constable today, but it could be anybody tomorrow," it continued. Any human being who is deprived of sleep will eventually fall asleep wherever. As a result, leisure and sleep are regarded as crucial components of the harmony that must be achieved between work and life.

According to a vigilance report dated April 23, 2024, the petitioner was discovered dozing off while on duty. The petitioner's sleep was captured on camera and shared on social media. The relevant authorities document the petitioner's explanation for his slumber, based on the recordings that have been making the rounds on social media or WhatsApp groups.

The Vigilance Department had also submitted a report stating there were only three KST constables in the depot; the workload on the exiting staff is exceedingly heavy and proposed recruiting two more constables.

Chandrashekar said in his statement that he had taken medication on the doctor's recommendation and that he had taken a 10-minute power nap because he works the second and third shifts continuously.

The corporation, however, argued that the petitioner was apprehended while dozing off while on duty. The petitioner was suspended because his sleeping was captured on camera and shared on social media, which damaged the Corporation's reputation.

Findings:
The judge observed that a KST constable works eight hours a day for the Corporation. Each of the three constables works eight hours a day. It is acknowledged that the petitioner was requested to perform double duty—that is, two shifts continuously for 16 hours per day—due to the heavy workload. It is reported that this continued for 60 days in a row.

According to Article 24 of the Universal Declaration of Human Rights, everyone has the right to leisure and relaxation, which includes the right to periodic paid holidays and a reasonable restriction on working hours.

"The International Labor Organization's covenants, of which the country is a member, recognize the balance between work and life," the bench stated. It is advised that, unless there are special circumstances, work hours should not exceed 48 hours per week and 8 hours per day.

"Employees in any organization, much less those working shifts, must have work and life balance," it stated after this. Therefore, given the unique circumstances of the case, there is no fault with the petitioner napping during duty hours.

"It would definitely become a misconduct if the petitioner had slept while on duty, when his duty was limited to a single shift," it continued.

"In the case at hand, the petitioner is made to overwork by two shifts of 16 hours, in 24 hours, for 60 long days without break," the court said, granting the motion. As a result, the respondent's decision to suspend the petitioner due to the respondent's foolishness is definitely one that lacks legitimacy; as a result, the order is unsupportable and should be abolished.

Citation No: 2025 LiveLaw (Kar) 76

Case Title: Chandrashekhar AND The Divisional Controller.

Case No: WRIT PETITION NO. 106142 OF 2024