Joseph vs Telangana State Road Transport Corporation 2025 INSC 920- Service Law - Disability Of Employee

Rights of Persons with Disabilities Act, 2016- When a disability is acquired in the course of service, the legal framework must respond not with exclusion but with adjustment. The duty of a public employer is not merely to discharge functionaries, but to preserve human potential where it continues to exist. The law does not permit the severance of service by the stroke of a medical certificate without first exhausting the possibility of meaningful redeployment. Such obligation is not rooted in compassion, but in constitutional discipline and statutory expectation -Even in the absence of such contractual rights, employees who acquire disabilities during service must not be abandoned or prematurely retired without being afforded a fair and reasonable opportunity for reassignment. The obligation to reasonably accommodate such employees is not just a matter of administrative grace, but a constitutional and statutory imperative, rooted in the principles of nondiscrimination, dignity, and equal treatment. (Para 35)

Rights of Persons with Disabilities Act, 2016- Even if colour blindness does not fall within the statutory definition of “disability” under Section 2(i) or “persons with disability” under Section 2(t) of the Rights of Persons with Disabilities Act, 2016, the employer is still bound to provide reasonable accommodation and cannot terminate employment without exploring alternate roles - Referred to Mohamed Ibrahim v. Chairman and Managing Director. (Para 33)

Constitution of India - Article 14,21 - Service Law - An employee who acquires a disability during service must be protected through reassignment where possible. The duty to reasonably accommodate such employees is now part of our constitutional fabric, rooted in Articles 14 and 21. (Para 41)

Constitution of India - Article 226 -While judicial restraint guards against overreach, it must not become an excuse for disengagement from injustice. When an employee is removed from service for a condition he did not choose, and where viable alternatives are ignored, the Court is not crossing a line by intervening, it is upholding one drawn by the Constitution itself. (Para 41)

Quotable Quotes - The employer’s discretion ends where the employee’s dignity begins.(Para 41) Inaction is not neutrality; in such cases, it is a form of institutional exclusion. (Para 26)

Industrial Disputes Act 1947 - Section 12(3) -Memorandum of Settlement is not a mere administrative circular—it is a binding statutory contract forged between labour and management (Para 18). Settlements entered under Section 12(3) are not administrative conveniences. They are quasi-statutory instruments reflecting negotiated justice, and they bind both employer and employee with the force of law. Where such settlements create specific entitlements, courts must give them purposive effect, unless expressly rescinded or demonstrably superseded. Their terms are not to be overridden by internal policy or circulars issued in contravention thereof. (Para 22)