Asked by a reader in Bengaluru

Am I a worker under the Industrial Relations Code, or am I excluded as a manager?

Answered by Advocate Sharan Jain··Employment & Labour Law

Legal Shorts · 75 words

Your actual work matters more than the word 'manager' on your appointment letter. The Industrial Relations Code covers specified manual, technical, operational, clerical and supervisory work, but excludes people mainly employed in managerial or administrative roles. Supervisors also face a wage-based exclusion. Gather your job description, reporting structure and examples of what you can actually approve. A high salary alone does not answer the question for every role. First identify which duties you mainly perform.

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This is the first question in almost every termination file, because the answer decides which forum you go to and what you can ask for. Since the four labour codes came into force on 21 November 2025, the word is "worker" rather than "workman", and the definition sits in Section 2 of the Industrial Relations Code, 2020.

A worker is a person employed in any industry to do any manual, unskilled, skilled, technical, operational, clerical or supervisory work for hire or reward, whether the terms of employment are express or implied. Working journalists and sales promotion employees are expressly included. For a dispute about a termination, a person already dismissed, discharged or retrenched in connection with that dispute is still a worker for the purpose of the proceeding.

The exclusions, which are where the argument happens

The same clause then carves out four categories. Two of them matter to office employees.

  • A person employed mainly in a managerial or administrative capacity. The word doing the work here is "mainly". A stray managerial task does not take you out.
  • A person employed in a supervisory capacity drawing wages exceeding eighteen thousand rupees a month, or such other amount as the Central Government may notify. Note the structure: the wage cap applies only to supervisory staff. It does not rescue a manager, and it does not exclude a clerical or technical employee however much that person earns.
  • Members of the armed forces, and persons employed in the police service or as officers or employees of a prison, are outside the definition altogether.

Because the threshold is expressed as a figure that the Central Government may replace by notification, check the notification in force rather than quoting the number from a blog post. The figure written into the Code is Rs 18,000; whether a higher amount has been notified is a question of fact on the date your dispute arose.

Two codes, two different figures
The Code on Wages, 2019 has its own definition of "worker" with its own supervisory cut off, set at fifteen thousand rupees a month, again subject to notification. The two codes are not interchangeable, and a Rs 16,000 supervisor can be a worker for the Industrial Relations Code and outside the wage Code's worker definition on the same facts. Read whichever Code gives the remedy you actually want. Our overview of what the four labour codes changed for employees sets the two definitions side by side.

The test the courts apply

Designation is not decisive, and Indian industrial adjudication has said so for decades. The enquiry is into the dominant nature of the duties actually performed. The questions that carry weight are practical ones:

  • Can you appoint, dismiss or discipline anyone
  • Can you sanction leave, approve expenses or sign off appraisals that bind the company
  • Do you allocate work and control how subordinates do it, or do you only report on it
  • Can you commit the employer contractually, or bind it to a customer
  • Do you set policy or budgets, or do you execute someone else's
  • How is your time actually spent, hour for hour, in a normal week

An employee who answers no to all of these is very likely a worker whatever the visiting card says. Our note on whether you count as a worker under the Industrial Relations Code works through the reported categories, including team leads, quality analysts, field engineers and branch staff.

Why the answer matters so much

If you are a worker, the Code gives you conditions precedent to retrenchment, a rule about the order of retrenchment within a category, a right of preference in re-employment, protection against listed unfair labour practices, conciliation before a conciliation officer and adjudication by an Industrial Tribunal, which can order reinstatement. If you are not a worker, none of that is available and your case is a contract case in a civil court, where reinstatement is not ordinarily granted because a contract of personal service is not specifically enforced. The remedy narrows to money.

The Karnataka answer sits alongside this one
For a shop, office or commercial establishment in Karnataka, the Karnataka Shops and Commercial Establishments Act, 1961 survives the codes, and its Section 39 gives an employee with six months of continuous service a right of appeal against removal or dismissal without reasonable cause. That route does not require you to win the "worker" argument. But it has an exclusion of its own: the Act does not apply to persons occupying positions of management in an establishment. So a genuine manager is outside both doors, and the honest answer for a genuine manager is a negotiated exit.

What to assemble before anyone argues about it

Status is proved by documents, not adjectives. Collect the appointment letter and every revision, the job description as issued, your appraisal forms including the section describing your responsibilities, the organisation chart, any approval matrix or delegation of authority, and a fair sample of your own emails showing what you spent the week doing. If you never had a subordinate, say so and show the chart. If you approved leave only by forwarding a request upward, keep the forward. Our guide on wrongful termination and employee rights in India sets out how the status question is pleaded and what the tribunal looks for.

One caution on timing. Conciliation cannot be held more than two years after the dispute arose, and an application to the Tribunal must follow within ninety days of receiving the conciliation officer's failure report. Settling the status question is not a reason to let those periods run.

Sources

The law this answer relies on, so you can read it yourself.

  1. 1.Industrial Relations Code, 2020 - 2(zr) Read the source
  2. 2.Industrial Relations Code (Amendment) Act, 2026 Read the source
  3. 3.Section 2, Industrial Relations Code, 2020. Definitions, including clause (zr) defining a worker as a person employed to do manual, unskilled, skilled, technical, operational, clerical or supervisory work, and excluding a person employed mainly in a managerial or administrative capacity and a person in a supervisory capacity drawing wages exceeding eighteen thousand rupees a month or such amount as the Central Government may notify. Read the source
  4. 4.Section 2, Code on Wages, 2019. Definitions, including clause (z) defining a worker and excluding a person employed mainly in a managerial or administrative capacity and a person in a supervisory capacity drawing wages exceeding fifteen thousand rupees a month or such amount as the Central Government may notify, which differs from the figure in the Industrial Relations Code, 2020. Read the source
  5. 5.Section 70, Industrial Relations Code, 2020. Conditions precedent to retrenchment: one month's notice in writing indicating the reasons or wages in lieu, compensation of fifteen days' average pay for every completed year of continuous service or part in excess of six months, and notice to the appropriate Government. Read the source
  6. 6.Section 53, Industrial Relations Code, 2020. Conciliation and adjudication of a dispute. The proviso to sub-section (1) bars conciliation proceedings more than two years after the dispute arose, and sub-section (6) allows ninety days from receipt of the conciliation officer's report to apply to the Tribunal. Read the source
  7. 7.Section 39, Karnataka Shops and Commercial Establishments Act, 1961. Notice of dismissal, requiring reasonable cause and one month's notice or pay in lieu for an employee with six months of continuous service, with a right of appeal to the prescribed authority, compensation capped at one month's pay for every year of service, and revision to the District Judge. Read the source
  8. 8.Section 3, Karnataka Shops and Commercial Establishments Act, 1961. Exemptions, including clause (1)(h), under which nothing in the Act applies to persons occupying positions of management in any establishment. Read the source

The short answer's sources were checked on 12 September 2026. Statutes and judgments can change, so check the current position before you act on anything here.

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This answer is the short version. These guides cover the same ground in full, with the procedure, the timelines and the leading cases.

SJ

Answered by

Advocate Sharan Jain

Advocate based in Bangalore, practising before the Karnataka High Court and District, Sessions, Consumer and Family courts. Answers public legal questions to make Indian law more accessible.

This answer is general information on Indian law as at August 8, 2026, published for public education. It is not legal advice, it does not take account of your facts, and reading it does not create an advocate-client relationship. Law changes and every case turns on its own circumstances. Please consult a qualified advocate about your own matter.

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