Bombay High Court Rejects Patanjali Foods' Reliance On NCLT Plan To Oppose Impleadment In Labour Case

On 7 September, the Nagpur Bench of the Bombay High Court rejected Patanjali Foods Ltd.'s challenge to its impleadment in a pending labour dispute concerning an employee of Ruchi Soya Industries Ltd.

Justice Nandesh S. Deshpande dismissed Patanjali Foods's writ petition and upheld the orders of the Labour Court and Industrial Court, while leaving it free to raise its defences based on the resolution plan before the Labour Court. The Bench held:

“Two factors are against the petitioner; firstly, the fact that the complaint before the Labour Court was pending when the resolution plan was approved by the NCLT; and secondly, prima facie, the concerned employee i.e. respondent No.1, was not informed about the resolution plan. Moreover, the Labour Court and the Industrial Court have not foreclosed the right of the petitioner. The petitioner can very well take such defences in the proceedings pending before the Labour Court.”

The dispute arose from a labour complaint filed by Shivshankar Singh against the General Manager of Ruchi Soya. After the Patanjali Group took over the business, Singh sought to implead Patanjali Foods in the proceedings.

The Labour Court allowed the application on 17 June 2025. The Industrial Court dismissed Patanjali Foods' revision on 24 March 2026, following which the company approached the High Court.

Patanjali Foods argued that the NCLT-approved resolution plan dated 24 July 2019, read with the provisions of the Insolvency and Bankruptcy Code, barred its addition as a party to the labour proceedings.

The High Court rejected reliance on an earlier Aurangabad Bench judgment, noting that the decision concerned an employee's entitlement to payment or other relief after approval of a resolution plan. It said that stage had not arisen in the present case.

It further noted that the Industrial Court had concurred with the Labour Court and found no ground to interfere, considering the limited jurisdiction available to it under Section 44 of the Maharashtra Recognition of Trade Unions and Prevention of Unfair Labour Practices Act, 1971. The Bench observed:

“The Industrial Court, which has concurred with the said order of the Labour Court has categorically held that looking to the limited jurisdiction vested in it under Section 44 of the Maharashtra Recognition of Trade Unions and Prevention of Unfair Labour Practices Act, 1971 no reason to interfere has been spelled out.”

Accordingly, the High Court dismissed the writ petition, discharging the rule with no order as to costs.

For Petitioner: Advocate Ranjan N. Deshpande

For Respondent: Advocate Rushikesh S. Bhoyar