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Section 20: Right to inspect books of Trade Union

The Industrial Relations Code, 2020 (Act No. 35 of 2020) • Official Statutory Text & Plain English Practice Guide

Statutory Mandate
Chapter III: Trade Unions
Competent Labour Forum
Act No. 35 of 2020
Section 19 All 104 Sections of Industrial Relations Code, 2020 Section 21

Legal Commentary & Landmark Judgments: Section 20

Section 20 of the Industrial Relations Code, 2020 guarantees every member and office-bearer the statutory right to inspect the account books, financial ledgers, and membership register of a registered Trade Union, enforcing internal democratic transparency and eliminating leadership concealment.

  • Mandatory Statutory Right of Inspection: Mandates that the account books of a registered Trade Union and the list of members thereof shall be open to inspection by an office-bearer or member at such times and under such conditions as may be provided in the registered rules of the Trade Union.
  • Democratic Safeguard Against Financial Mismanagement: Empowers rank-and-file union members to verify financial regularity, audit reports, subscription collections, and voting rosters, preventing executive concealment and unauthorized dissipation of general funds.
  • Prohibition Against Unreasonable Restrictions: While the union's registered rules may prescribe reasonable hours and administrative notice for inspection, they cannot impose prohibitive fees, discretionary vetting, or onerous conditions that defeat the statutory right.
Key Landmark Precedents:
  • Cheditha v. Registrar of Trade Unions AIR 1957 All 750: The Allahabad High Court held that the right of a member to inspect trade union accounts and membership registers is an absolute statutory right that cannot be defeated by arbitrary executive refusal or procedural stalling.
  • Bokaro Steel Workers Union v. State of Bihar 1995 Supp (1) SCC 20: The Supreme Court noted that inspection of the membership register is fundamental to maintaining internal union democracy, ensuring that election voter rolls accurately reflect bona fide contributing members.
  • M.T. Chandrasenan v. Sukumaran (1974) 2 SCC 853: The Supreme Court emphasized that transparency in membership records and financial management is essential to prevent factional manipulation and fraudulent voter inflation in trade unions.
Courtroom Practice & Strategic Litigation Guidance:

Trade Union executives must maintain a dedicated Inspection Log at the registered office and notify members of fixed weekly inspection hours (e.g., every Saturday afternoon). If union officers refuse a written inspection request, dissident members should serve a formal 7-day legal notice under Section 20, followed immediately by an application before the Industrial Tribunal under Section 23 seeking an order directing inspection under court-appointed supervision.

Section 19 All 104 Sections of Industrial Relations Code, 2020 Section 21