Section 27 of the Indian Contract Act
Agreement in Restraint of Trade Void - Every agreement by which anyone is restrained from exercising a lawful profession, trade, or business of any kind is to that extent void (i.e., illegal).
Only exception to this section is that:
Exception-1: Saving of agreement not to carry on business of which goodwill is sold - One who sells the goodwill of a business may agree with the buyer to refrain from carrying on a similar business within specified local limits, so long as the buyer, or any person deriving title to the goodwill from him, carries on a like business therein, provided that such limits appear to the Court reasonable, regard being had to the nature of the business.
In Superintendence Company of India Vs Krishna (1980 AIR 1717), the Supreme Court held that a contract for restraint of trade is one by which a party restrains his future liability to carry on his trade, business, or profession in such manner and with such persons as he chooses. A contract of such class is prima facie void.
In Pepsi Foods Limited and Others v Bharat Coca-Cola Holdings Pvt. Ltd. and Others (1981-1985 DLT-), the Delhi High Court has held that freedom of changing employment for improving service conditions is a vital and important right of an employee, which cannot be restricted or curtailed by a Court injunction.
The learned Single Judge of the Delhi High Court in Ambience India Private Limited v Naveen Jain (2005 (3) KLT SN 61) observed that the law is well settled that all contracts in restraint of trade are void and hit by Section 27 of the Contract Act. He also held the prima facie view that the agreement between the parties prohibiting the defendant for two years from taking employment with any present, past, or prospective customer of the plaintiff is void and hit by Section 27 of the Indian Contract Act. The court also held that the employment contract between the plaintiff and defendant was determinable in nature, and as such, the defendant was entitled to determine the same and seek another employment. Everybody has a right to strive for progress in career. The restrictions imposed upon the defendant in the agreement, therefore, were void and unconscionable.
In Star India Private Limited v. Laxmiraj Seetharam Nayek and Another, the Bombay Court observed that if the plaintiff had the right to terminate the contract on the ground of misconduct, it cannot be said that the Defendant had absolutely no right to resign from the employment on account of better prospects or other personal reasons. If he finds better employment with better remuneration and other service conditions, he cannot be tied down under the terms of the service contract. The Court held that any agreement restraining an employee, post-termination, from seeking employment elsewhere is void.
In R. Babu and Another v. TTK LIG Ltd Chennai (2005 LLR 71 (Mad. HC)), the court vacated the injunction order issued by the learned Judge whereby an employee, after tendering his resignation, joined another company notwithstanding that he had entered into an agreement that after cessation of his employment with the company, he would not seek any employment in any establishment elsewhere of similar nature for a period of five years. The Court held that an agreement whereby an employee agrees not to join another competitive concern for a specified period after cessation of his employment will violate public policy as stipulated by the Indian Contract Act, hence it cannot be legally enforced in the Court.
Even if you quote 100 cases pertaining to Section 27 of contracts and Article 19, it is clearly established in India that bonds which hinder the development of the individual, and the bonds which are void ab initio, the bonds of mala fide intentions, acts impossible to do anymore, would only be made exceptions. In this case, it is only for 3 years, and that too are bifurcated. Secondly, the purpose is clearly established, both parties benefit from it. Thirdly, terms and conditions of the contract and any clauses in it do not prove mala fide intentions nor do they highlight exploitation. And, as discussed earlier, it is very true and agreed that nobody can force anyone to do anything. In such cases, the other party who undergoes the losses cannot keep quiet in silence; he also has the right in personam to get what he was asked for and invested upon, so can always claim either for specific performance, surely for compensation and damages.
I kindly request you to read the case completely, and please know the difference between complete restraining/restrictions and reasonable restrictions, because the cases you have referred to are irrelevant in this matter. I would rather request you to check out the case for "breach of employment contracts" in which the rights and liabilities of the employer and employee are discussed, and also refer to the cases under the Apprenticeship Act.
In this case, if the agreement is valid and the employer is bona fide mens mentis, then the candidate here can never escape the liability.
In simple words, nobody can force you to do the act, but once you have agreed to do the act, which is legal and possible to be completed, then you are liable for whatever you agreed to. In case of your failure to do such acts agreed upon, you will have to pay the compensation and damages to the other party.
Just think generally, if whatever the cases mentioned there apply in every case, what should the employers do? Everyone leaves after the training. Who will substantiate the losses and what is the return on investment?
If you still cannot grasp the points said, I can explain the same by taking each case being quoted and how they are not relevant in this particular matter, and how the issues completely differ.
Both parties are equally supported by law, whatever may be the matter. After all, natural justice can never be ignored.