{"id":124849,"date":"1994-10-20T00:00:00","date_gmt":"1994-10-19T18:30:00","guid":{"rendered":"https:\/\/www.legalindia.com\/judgments\/municipal-corporation-of-delhi-vs-razak-on-20-october-1994"},"modified":"2015-11-16T10:29:23","modified_gmt":"2015-11-16T04:59:23","slug":"municipal-corporation-of-delhi-vs-razak-on-20-october-1994","status":"publish","type":"post","link":"https:\/\/www.legalindia.com\/judgments\/municipal-corporation-of-delhi-vs-razak-on-20-october-1994","title":{"rendered":"Municipal Corporation Of Delhi vs Razak on 20 October, 1994"},"content":{"rendered":"
Supreme Court of India<\/div>\n
Municipal Corporation Of Delhi vs Razak on 20 October, 1994<\/div>\n
Equivalent citations: 1995 SCC (1) 235, \t JT 1994 (7)\t476<\/div>\n
Author: J S Verma<\/div>\n
Bench: Verma, Jagdish Saran (J)<\/div>\n
           PETITIONER:\nMUNICIPAL CORPORATION OF DELHI\n\n\tVs.\n\nRESPONDENT:\nRAZAK\n\nDATE OF JUDGMENT20\/10\/1994\n\nBENCH:\nVERMA, JAGDISH SARAN (J)\nBENCH:\nVERMA, JAGDISH SARAN (J)\nBHARUCHA S.P. (J)\nPARIPOORNAN, K.S.(J)\n\nCITATION:\n 1995 SCC  (1) 235\t  JT 1994 (7)\t476\n 1994 SCALE  (4)967\n\n\nACT:\n\n\n\nHEADNOTE:\n\n\n\nJUDGMENT:\n<\/pre>\n
The  Judgment of the Court was delivered by J.S. VERMA,\t J.-
\nLeave granted.\n<\/p>\n
2.   The  common question for decision in these\t matters  is
\nthe   maintainability  of  the\tclaim  of   respondents\t  in
\nproceedings under Section 33-C(2) of the Industrial Disputes
\nAct,  1947  (hereinafter  referred to as  ‘the\tAct’).\t The
\nrespondents  are  all  daily-rated\/casual  workers  of\t the
\nappellant  Municipal  Corporation of Delhi, who\t claim\tthat
\nthey  were  doing  the\tsame kind of  work  as\tthe  regular
\nemployees  and, therefore, they were required to be paid  by
\nthe  appellant the same pay as the regular employees on\t the
\nprinciple  of  “equal pay for equal work”.  On\tthis  basis,
\nthey claim computation of the arrears of their wages at\t the
\nrate  at which the wages are paid to the regular  employees,
\nin  accordance\twith  Section 33-C(2)  of  the\tAct.   Their
\napplications made to the Labour Court under Section  33-C(2)
\nof the Act led to the award in their favour, accepting\tthis
\nclaim.\tWrit petitions were filed in the Delhi High Court by
\nthe   appellant-Municipal  Corporation\t challenging   those
\nawards.\t  The  writ petitions having been  dismissed,  these
\nappeals arise by special leave.\n<\/p>\n
237<\/span><\/p>\n
3.   The appellant’s challenge to the maintainability of the
\nrespondents’  claim in proceedings under Section 33-C(2)  of
\nthe  Act  is on the ground that the claim of workmen  to  be
\npaid at the same rate as the regular workmen being disputed,
\nproceedings  under  Section  33-C(2) of\t the  Act  were\t not
\nmaintainable  for  grant of this relief.  The  Labour  Court
\nand,   thereafter,  the\t High  Court  have   rejected\tthis
\ncontention.   The same argument is reiterated before  us  in
\nthese appeals.\n<\/p>\n
4.   It is clear that there has been no earlier adjudication
\nby  any\t forum\tof  the claim  of  these  workmen  of  their
\nentitlement  to be paid wages at the same rate at which\t the
\nregular\t workmen  of the establishment are  being  paid\t and
\nthere  is no award or settlement to that effect.  In  short,
\nthis  claim of the workmen has neither been adjudicated\t nor
\nrecognised by the employer in any award or settlement.\t The
\nreal question therefore is : Whether in these circumstances,
\nwithout a prior adjudication or recognition of the  disputed
\nclaim  of  the workmen to be paid at the same  rate  as\t the
\nregular\t employees,  proceedings  for  computation  of\t the
\narrears\t of  wages  claimed  by\t them  on  that\t basis\t are
\nmaintainable under Section 33-C(2) of the Act?\n<\/p>\n
5.   In our opinion, the question for decision is no  longer
\nres integra being long settled by earlier decisions of\tthis
\nCourt.\tSome of the decisions have been referred by the High
\nCourt  in the impugned judgment, but the application of\t the
\nsettled\t principle made by the High Court is erroneous.\t  We
\nwould  refer to some of the decisions on this point and\t the
\nsubmissions   of  learned  counsel  for\t the  parties\twith
\nreference to which these matters have to be decided.\n<\/p>\n
6.   Shri  G.B.\t Pai,  learned counsel\tfor  the  appellant,
\nsubmitted that the proceedings under Section 33-C(2) of\t the
\nAct  are  in  the  nature  of  execution  proceedings  which
\nenvisage a prior adjudication or recognition by the employer
\nof the claim of the workmen to be paid wages at the rate ;At
\nwhich  they  claim the computation; and when  the  basis  of
\ntheir claim is disputed, the remedy under Section 33-C(2) is
\nnot  available to the workmen.\tShri Pai contended  that  in
\nthe  present  case,  there was no  earlier  adjudication  or
\nrecognition  of the workmen’s claim to be paid at  the\tsame
\nrate  as  the regular workmen and, therefore, the  basis  of
\ncomputation  being disputed, the proceedings  under  Section
\n33-C(2) of the Act were not maintainable.  According to Shri
\nPai,  this  is\tthe sit tight  position\t emerging  from\t the
\ndecisions of this Court.\n<\/p>\n
7.   On\t the other hand, Shri PP.  Rao, learned counsel\t for
\nthe  respondent workmen submitted that there was  really  no
\ndispute of this kind since these daily-rated\/casual  workmen
\nwere doing the same kind of work as the regular workmen and,
\ntherefore,  they were entitled to be paid wages at the\tsame
\nrate  as the regular workmen on the principle of “equal\t pay
\nfor  equal  work”.  It was submitted that  in  certain\twrit
\npetitions filed by some other workmen, it had been held that
\nthey  were  required  to be paid at the\t same  rate  as\t the
\nregular workmen and, therefore, it would not be open to\t the
\nemployer  to  raise  such a dispute in\tthe  case  of  other
\nworkmen such as the present
\n238<\/span>
\nrespondents.   According  to  Shri  Rao,  proceedings  under
\nSection 33-C(2) of the Act were maintainable in these  cases
\nand the Labour Court as well as the High Court are right  in
\ntaking that view.  Shri Rao formulated his contention  thus:
\nThe very dispute as to entitlement of the benefit claimed by
\nthe  workmen as well as the computation thereof\t are  within
\nthe scope of Section 33-C(2) of the Act.\n<\/p>\n
8.Reference  may  be made first to  the\t Constitution  Bench
\ndecision in Central Bank of India Ltd. v. PS.\tRajagopalan1
\non which Shri Rao placed heavy reliance.  That was a case in
\nwhich  the question of maintainability of proceedings  under
\nSection 33-C(2) of the Act was considered in a claim made by
\nthe workmen on the basis of the Sastry Award.  The  employer
\ndisputed  the  claim  of  the  workmen\ton  several  grounds
\nincluding  the applicability of Section 33-C(2) of the\tAct.
\nIt was urged that since the applications involved a question
\nof interpretation of the Sastry Award, they were outside the
\npurview of Section 33-C(2) because interpretation of  awards
\nor  settlements has been expressly provided for\t by  Section
\n36-A.  This objection was rejected.  This Court pointed\t Out
\nthe difference in the scope of Section 36-A and Section\t 33-
\nC(2)  indicating that the distinction lies in the fact\tthat
\nSection\t 36-A  is not concerned with the  implementation  or
\nexecution  of the award whereas that is the sole purpose  of
\nSection\t 33-C(2);  and whereas Section\t33-C(2)\t deals\twith
\ncases  of  implementation of individual\t rights\t of  workmen
\nfalling under its provisions, Section 36-A deals merely with
\na  question of interpretation of the award where  a  dispute
\narises in that behalf between the workmen and tile  employer
\nand  the  appropriate  Government  ‘Is\tsatisfied  that\t the
\ndispute\t deserves to be resolved by reference under  Section
\n36-A.\tIn this context, this Court also indicated that\t the
\npower of the Labour Court in a proceeding under Section\t 33-
\nC(2)  being akin to that of the Executing Court, the  Labour
\nCourt  is competent to interpret the award or settlement  on
\nwhich a workman bases his claim under Section 33-C(2),\tlike
\nthe power of the Executing Court to interpret the decree for
\nthe  purpose  of  execution.   Relevant\t extract  from\tthat
\ndecision is as under: (SCR pp. 154-155)
\n\t      “Besides, there can be no doubt that when\t the
\n\t      Labour  Court is given the power to  allow  an
\n\t      individual workman to execute or implement his
\n\t      existing\tindividual rights, it  is  virtually
\n\t      exercising execution powers in some cases, and
\n\t      it  is  well settled that it is  open  to\t the
\n\t      Executing\t Court to interpret the\t decree\t for
\n\t      the  purpose of execution.  It is, of  course,
\n\t      true that the Executing Court cannot go behind
\n\t      the decree, nor can it add to or subtract from
\n\t      the   provision\tof   the   decree.     These
\n\t      limitations  apply also to the  Labour  Court;
\n\t      but like the Executing Court, the Labour Court
\n\t      would also be competent to interpret the award
\n\t      or  settlement  on which a workman  bases\t his
\n\t      claim  under Section 33-C(2).   Therefore,  we
\n\t      feel  no\tdifficulty in holding that  for\t the
\n\t      purpose of making the necessary  determination
\n\t      under   Section\t33-C(2),   it\twould,\t  in
\n\t      appropriate cases, be
\n\t      1\t (1964) 3 SCR 140: AIR 1964 SC 743:(1963)  2
\n\t      LLJ 89
\n\t      239<\/span>
\n\t      open  to\tthe Labour Court  to  interpret\t the
\n\t      award  or\t settlement on which  the  workman’s
\n\t      right rests.”\n<\/p>\n
This decision itself indicates that the power of the  Labour
\nCourt under Section 33-C(2) extends to interpretation of the
\naward or settlement on which the workman’s right rests, like
\nthe Executing Court’s power to interpret the decree for\t the
\npurpose\t of  execution,\t where the basis  of  the  claim  is
\nreferable to the award or settlement, but it does not extend
\nto determination of the dispute of entitlement or the  basis
\nof   the  claim\t if  there  be\tno  prior  adjudication\t  or
\nrecognition  of\t the same by the  employer.   This  decision
\nnegatives  instead of supporting the submission\t of  learned
\ncounsel for the\t    respondents.\n<\/p>\n
9.   Another decision on the point is Bombay Gas Co. Ltd. v.
\nGopal Bhiva2<\/a>   wherein also Gajendragadkar, J., (as he\tthen
\nwas) speaking for the Bench,  referring\t   to\tthe    above
\nConstitution  Bench  decision, stated that  the\t proceedings
\ncontemplated  by Section 33-C(2) are analogous to  execution
\nproceedings  and the Labour Court, like the Executing  Court
\nin  the execution proceedings governed by the Code of  Civil
\nProcedure,  would  be competent to interpret  the  award  on
\nwhich  the claim is based.  It is obvious that the power  of
\nthe  Executing Court is only to implement  the\tadjudication
\nalready\t made by a decree and not to adjudicate\t a  disputed
\nclaim which requires adjudication for its enforcement in the
\nform  of decree.  The Executing Court, after the decree\t has
\nbeen  passed, is however competent to interpret\t the  decree
\nfor  the purpose of its implementation.\t This  position\t was
\nsettled\t by  the above Constitution Bench decision  and\t has
\nbeen the consistent view of this Court ever since then.\n<\/p>\n
10.  Next  case on this point is Chief Mining Engineer\tEast
\nIndia  Coal  Co.   Ltd.\t v.  Rameswar3\twherein\t the   above
\ndecisions were relied on.  It was held that the right to the
\nbenefit which is sought to be computed under Section 33-C(2)
\nmust   be  “an\texisting  one,\tthat  is  to  say,   already
\nadjudicated upon or provided for”.  The propositions on\t the
\nquestion  as to the scope of Section 33-C(2) deducible\tfrom
\nthe earlier decisions of this Court were summarised and they
\ninclude the following, namely: (SCR pp. 142-144)
\n\t      “(1)  The legislative history  indicates\tthat
\n\t      the  legislature, after providing broadly\t for
\n\t      the  investigation and settlement of  disputes
\n\t      on   the\tbasis  of   collective\t bargaining,
\n\t      recognised the need of individual workmen of a
\n\t      speedy   remedy  to  enforce  their   existing
\n\t      individual   rights  and\ttherefore   inserted
\n\t      Section 33-A in 1950 and Section 33-C in 1956.
\n\t      These  two sections illustrate cases in  which
\n\t      individual  workmen can enforce  their  rights
\n\t      without  having  to take recourse\t to  Section
\n\t      10(1)  and without having to depend  on  their
\n\t      union to espouse their case.\n<\/p>\n
\t      2 (1964) 3 SCR 709: AIR 1964 SC 752 : (1963) 2
\n\t      LLJ 608
\n\t      3 (1968) 3 SCR 140: AIR 1968 SC 218 : (1968) 1
\n\t      LLJ 6
\n\t      240<\/span>
\n\t      (3)   Section  33-C which is in terms  similar
\n\t      to  those\t in  Section 20\t of  the  Industrial
\n\t      Disputes\t(Appellate Tribunal) Act, 1950 is  a
\n\t      provision\t in  the  nature  of  an   executing
\n\t      provision.\n<\/p>\n
\t      (5)   Section 33-C(2) takes within its purview
\n\t      cases of workmen who claim that the benefit to
\n\t      which they are entitled should be computed  in
\n\t      terms  of money even though the right  to\t the
\n\t      benefit  on  which  their claim  is  based  is
\n\t      disputed\tby their employers.  It is  open  to
\n\t      the  Labour  Court to interpret the  award  or
\n\t      settlement on which the workmen’s right rests.
\n\t      (7)   Though the court did not indicate  which
\n\t      cases  other than those under sub-section\t (1)
\n\t      would  fall under sub-section (2), it  pointed
\n\t      out  illustrative cases which would  not\tfall
\n\t      under sub-section (2), viz., cases which would
\n\t      appropriately  be\t adjudicated  under  Section
\n\t      10(1)  or claims which have already  been\t the
\n\t      subject-matter of settlement to which Sections
\n\t      18 and 19 would apply.\n<\/p>\n
\t      (8)   Since proceedings under Section  33-C(2)
\n\t      are analogous to execution proceedings and the
\n\t      Labour  Court called upon to compute in  terms
\n\t      of  money the benefit claimed by a workman  is
\n\t      in such cases in the position of an  Executing
\n\t      Court,  the  Labour Court like  the  Executing
\n\t      Court in execution proceedings governed by the
\n\t      Code  of Civil Procedure, is  competent  under
\n\t      Section  33-C(2)\tto interpret  the  award  or
\n\t      settlement where the benefit is claimed  under
\n\t      such award or settlement and it would be\topen
\n\t      to  it to consider the plea of  nullity  where
\n\t      the award is made without,jurisdiction.”
\n\t      After  stating the propositions, the  decision
\n\t      proceeds to state as under: (SCR p. 144)
\n\t      ”\t It is clear that the right to\tthe  benefit
\n\t      which  is\t sought to be computed\tmust  be  an
\n\t      existing\t one,  that  is\t to   say,   already
\n\t      adjudicated  upon\t or provided  for  and\tmust
\n\t      arise in the course of and in relation to\t the
\n\t      relationship between an industrial workman and
\n\t      his employer.”\n<\/p>\n
11.  In\t Central  Inland  Water Transport  Corpn.   Ltd.  v.
\nWorkmen4 it was held with reference to the earlier decisions
\nthat a proceeding under Section 33-C(2) being in the  nature
\nof  an\texecution  proceeding,\tit  would  appear  that\t  an
\ninvestigation  of  the\talleged right  of  re-employment  is
\noutside\t its  scope and the Labour  Court  exercising  power
\nunder  Section 33-C(2) of the Act cannot arrogate to  itself
\nthe functions of adjudication of the dispute relating to the
\nclaim of re-employment.\t Distinction between proceedings  in
\na suit and execution proceedings thereafter was pointed out.
\nIt  was\t indicated  that the  plaintiff’s  right  to  relief
\nagainst the defendant involves an investigation which can be
\ndone  only in a suit and once the defendant’s liability\t had
\nbeen  adjudicated  in  the suit, the  working  out  of\tsuch
\nliability with a view to give
\n4 (1974) 4 SCC 696: 1974 SCC (L&S) 421 :(1975) 1 SCR 153
\n241<\/span>
\nrelief\tis  the function of an execution  proceeding.\tThis
\ndistinction  is\t clearly  brought out in  that\tdecision  as
\nunder: (SCR p. 159 : SCC pp. 701-02)
\n\t      “In  a  suit, a claim for relief made  by\t the
\n\t      plaintiff\t against the defendant\tinvolves  an
\n\t      investigation directed to the determination of\n<\/p>\n
\t      (i) the plaintiff’s right to relief; (ii)\t the
\n\t      corresponding  liability\tof  the\t  defendant,
\n\t      including,  whether the defendant is, at\tall,
\n\t      liable  or  not; and (iii) the extent  of\t the
\n\t      defendant’s  liability, if any.\tThe  working
\n\t      out  of  such liability with a  view  to\tgive
\n\t      relief  is generally regarded as the  function
\n\t      of an execution proceeding.  Determination No.\n<\/p>\n
\t      (iii)  referred to above, that is to say,\t the
\n\t      extent   of  the\tdefendant’s  liability\t may
\n\t      sometimes\t be left over for  determination  in
\n\t      execution\t proceedings.  But that is  not\t the
\n\t      case  with the determinations under heads\t (i)
\n\t      and  (ii).  They are normally regarded as\t the
\n\t      functions\t of  a\tsuit and  not  an  execution
\n\t      proceeding.  Since a proceeding under  Section
\n\t      33-C(2)  is  in  the nature  of  an  execution
\n\t      proceeding   it\tshould\t follow\t  that\t  an
\n\t      investigation of the nature of  determinations\n<\/p>\n
\t      (i)  and (ii) above is, normally, outside\t its
\n\t      scope.  It is true that in a proceeding  under
\n\t      Section\t33-C(2),   as\tin   an\t   execution
\n\t      proceeding,  it may be necessary to  determine
\n\t      the identity of the person by whom or  against
\n\t      whom the claim is made if there is a challenge
\n\t      on   that\t  score.    But\t  that\t is   merely
\n\t      ‘Incidental’.  To call determinations (i)\t and\n<\/p>\n
\t      (ii)  ‘Incidental’ to an execution  proceeding
\n\t      would  be\t a  perversion,\t because   execution
\n\t      proceedings  in which the extent of  liability
\n\t      is worked out are just consequential upon\t the
\n\t      determinations (i) and (ii) and represent\t the
\n\t      last  stage  in  a process  leading  to  final
\n\t      relief.\tTherefore,  when  a  claim  is\tmade
\n\t      before the Labour Court under Section  33-C(2)
\n\t      that   court  must  clearly   understand\t the
\n\t      limitations under which it is to function.  It
\n\t      cannot arrogate to itself the functions-say of
\n\t      an Industrial Tribunal which alone is entitled
\n\t      to   make\t adjudications\tin  the\t nature\t  of
\n\t      determinations (i) and (ii) referred to above,
\n\t      or  proceed to compute the benefit by  dubbing
\n\t      the   former  as\t‘Incidental’  to  its\tmain
\n\t      business\tof  computation.   In  such   cases,
\n\t      determinations   (i)   and   (ii)\t  are\t not
\n\t      ‘Incidental’   to\t  the\tcomputation.\t The
\n\t      computation  itself is consequential upon\t and
\n\t      subsidiary  to determinations (i) and (ii)  as
\n\t      the last stage in the process which  commenced
\n\t      with  a reference to the Industrial  Tribunal.
\n\t      It  was,\ttherefore,  held in  State  Bank  of
\n\t      Bikaner and Jaipur v. R.L. Khandelwal5<\/a> that  a
\n\t      workman  cannot  put  forward a  claim  in  an
\n\t      application  under Section 33-C(2) in  respect
\n\t      of a matter which is not based on an  existing
\n\t      right  and  which\t can  be  appropriately\t the
\n\t      subject matter of an industrial dispute  which
\n\t      requires\ta reference under Section IO of\t the
\n\t      Act.”\n<\/p>\n
12.The\tHigh Court has referred to some of  these  decisions
\nbut  missed  the true import thereof.  The  ratio  of  these
\ndecisions clearly indicates that where the very basis of the
\nclaim or the entitlement of the workmen to a certain benefit
\nis  disputed,  there  being,  no  earlier  adjudication\t  or
\nrecognition
\n5 (1968) 1 LLJ 589 : 38 Comp Cas 400 (SC)
\n242<\/span>
\nthereof by the employer, the dispute relating to entitlement
\nis not incidental to the benefit claimed and is,  therefore,
\nclearly outside the scope of a proceeding under Section\t 33-
\nC(2)  of the Act.  The Labour Court has no  jurisdiction  to
\nfirst  decide the workmen’s entitlement and then proceed  to
\ncompute the benefit so adjudicated on that basis in exercise
\nof  its power under Section 33-C(2) of the Act.\t It is\tonly
\nwhen  the  entitlement\thas  been  earlier  adjudicated\t  or
\nrecognised  by tile employer and thereafter for the  purpose
\nof  implementation  or enforcement  thereof  some  ambiguity
\nrequires  interpretation that the interpretation is  treated
\nas incidental to the Labour Court’s power under Section\t 33-
\nC(2)  like that of the Executing Court’s power to  interpret
\nthe decree for the purpose of its execution.\n<\/p>\n
13.In these matters, the claim of the respondent-workmen who
\nwere all daily-rated\/casual workers, to be paid wages at the
\nsame  rate  as\tthe regular workers, had  not  been  earlier
\nsettled\t by  adjudication  or recognition  by  the  employer
\nwithout\t which\tthe stage for computation  of  that  benefit
\ncould not reach.  The workmen’s claim of doing the same kind
\nof  work and their entitlement to be paid wages at the\tsame
\nrate  as the regular workmen on the principle of “equal\t pay
\nfor  equal work” being disputed, without an adjudication  of
\ntheir dispute resulting in acceptance of their claim to this
\neffect,\t there could be no occasion for computation  of\t the
\nbenefit on that basis to attract Section 33-C(2).  The\tmere
\nfact  that  some other workmen are alleged to  have  made  a
\nsimilar\t claim by filing writ petitions under Article 32  of
\nthe Constitution is indicative of the need for\tadjudication
\nof   the  claim\t of  entitlement  to  the   benefit   before
\ncomputation of such a benefit could be sought.\tRespondents’
\nclaim is not based on a prior adjudication made in the\twrit
\npetitions  filed by some other workmen upholding  a  similar
\nclaim which could be relied on as an adjudication enuring to
\nthe  benefit  of  these\t respondents  as  well.\t  The\twrit
\npetitions by some other workmen to which some reference\t was
\ncasually  made,\t particulars of which are not  available  in
\nthese matters, have, therefore, no relevance for the present
\npurpose.  It must, therefore, be held that the Labour  Court
\nas  well  as  the High Court were in error  in\ttreating  as
\nmaintainable the applications made Linder Section 33-C(2) of
\nthe Act by these respondents.\n<\/p>\n
14.Consequently,  these appeals are allowed.  The  judgments
\nof  the High Court as well as the awards made by the  Labour
\nCourt in favour of the respondents are set aside.  No costs.\n<\/p>\n
243<\/span><\/p>\n","protected":false},"excerpt":{"rendered":"
Supreme Court of India Municipal Corporation Of Delhi vs Razak on 20 October, 1994 Equivalent citations: 1995 SCC (1) 235, JT 1994 (7) 476 Author: J S Verma Bench: Verma, Jagdish Saran (J) PETITIONER: MUNICIPAL CORPORATION OF DELHI Vs. RESPONDENT: RAZAK DATE OF JUDGMENT20\/10\/1994 BENCH: VERMA, JAGDISH SARAN (J) BENCH: VERMA, JAGDISH SARAN (J) BHARUCHA […]<\/p>\n","protected":false},"author":1,"featured_media":0,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"_lmt_disableupdate":"","_lmt_disable":"","_jetpack_memberships_contains_paid_content":false,"footnotes":""},"categories":[30],"tags":[],"class_list":["post-124849","post","type-post","status-publish","format-standard","hentry","category-supreme-court-of-india"],"yoast_head":"\nMunicipal Corporation Of Delhi vs Razak on 20 October, 1994 - Free Judgements of Supreme Court & High Court | Legal India<\/title>\n<meta name=\"robots\" content=\"index, follow, max-snippet:-1, max-image-preview:large, max-video-preview:-1\" \/>\n<link rel=\"canonical\" href=\"https:\/\/www.legalindia.com\/judgments\/municipal-corporation-of-delhi-vs-razak-on-20-october-1994\" \/>\n<meta property=\"og:locale\" content=\"en_US\" \/>\n<meta property=\"og:type\" content=\"article\" \/>\n<meta property=\"og:title\" content=\"Municipal Corporation Of Delhi vs Razak on 20 October, 1994 - 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