ISSUE:
Whether the publication of an industrial award under Section 17(1) of the Industrial Disputes Act, 1947, is mandatory, or can it be withheld in special circumstances?
Whether a binding settlement under Section 18(1) can prevent the publication of an award that would otherwise become binding under Section 18(3)?
RULE:
Mandatory Nature of Section 17(1): The Supreme Court held that, as a general rule, the Government is bound to publish an award within 30 days of receipt under Section 17(1), reinforcing its mandatory nature. However, this mandate is not absolute and must be reconciled with other provisions of the Act.
Reconciliation with Section 18(1): The Court ruled that when a binding settlement under Section 18(1) is reached before publication, the award becomes redundant, and the Government must withhold publication to avoid unnecessary industrial conflict.