Yes even partial stoppage of work for 3 hours 30 minutes would be considered as strike.
"Strike" means a cessation of work by a body of persons employed in any industry, acting in combination or a concerted refusal, or a refusal under a common understanding, of any number of persons who are or have been so employed to continue to work or to accept employment.
The definition and use of the word 'strike' has been going transformation around the basic concept of stoppage of work or quitting of work by employees in their economic struggle with capital. In order to constitute strike in its technical sense it is necessary that there should be cessation of work but it is not necessary that there must be total suspension of work because even partial stoppage of work for 3 hours 30 minutes would be strike. So, cessation of work for short duration will also be strike. The Courts in India have even gone to the extent of observing that cessation of work even for 15 to 20 minutes or half-an-hour is strike, provided it is established that the workmen not off their duty and were required to report and work during the said period and the cessation of work was in concert. The term 'concert' means 'to accord together'. It would thus be seen that the action of an individual who absents himself to enforce a demand for higher wages shall not constitute strike. The reason is that the term 'strike' in its broad significance has reference to a dispute between employer and employees in the course of which there is concerted suspension of employment. The other important ingredient to constitute strike is that 'cessation of work in concert' should be in defiance of management's authority. To summarise, the essential ingredients of the definition of 'strike' as given in Section. 2(q) of the Act may be treated under the following heads:
Cessation of work or refusal of work
(a). Cessation of work:
there should be cessation of work, and
such cessation should be by a body of persons employed in the industry acting in combination, or
(b). Refusal to work:
there should be concerted refusal under a common understanding, and
such refusal should be by any number of persons employed in the industry to continue to work or to accept employment.
Thus the definition of 'strike' postulates three main ingredients, namely,
plurality of workmen,
cessation of work or refusal to do work, and
combined or concerted action.
The first pre-requisite of strike is cessation of work. Hunger-strike cannot, therefore, be called strike in as much as in hunger strike there need not necessarily be cessation of work. But when hunger strike is accompanied by cessation or suspension of work, then that would, 'of course constitute strike'. Similarly, 'go-slow' would not technically be a strike though go-slow tactics also are generally resorted to by the workers for compelling the employer to yield to their demand. The workers have got the right to strike but there is no such right to adopt 'go-slow' tactics which are more reprehensible in character than strike. Some difficulty may, however, arise in distinguishing 'go-slow tactics' from 'stay-in strike'. In case the workers do not work at all, that will, of course, amount to strike notwithstanding that they make the pretence of working. If, however, the quantum of work is much below the usual quantum of work, then it will technically be go-slow. In fact, 'go-slow' is a technical word which is used in describing the tactics of workmen when they reduce the speed of work or adopt dilatory tactics to reduce the usual production while pretending to be engaged on work.