ISSUE:
Whether the Government’s reference under Section 10(1)(c) of the Industrial Disputes Act, 1947, was valid despite not specifying the exact disputes or the parties involved?
Whether an industrial dispute existed or was apprehended in relation to Prabhat Talkies, making it subject to the Tribunal’s award?
RULE:
A reference under Section 10(1) is an administrative act, not a judicial or quasi-judicial determination. The Government is not required to ascertain or specify the precise disputes before making a reference; it need only form an opinion that an industrial dispute exists or is apprehended. The validity of such a reference cannot be questioned merely because it lacks detailed particulars.
An industrial dispute is not confined to actual disputes between individual employers and employees. A collective dispute raised by a trade union on behalf of workers in an industry can justify a reference, even if some establishments claim no internal discord. The Tribunal’s jurisdiction extends to settling such disputes affecting the industry as a whole.