ISSUE:
Whether the State Government was justified in refusing to make a reference under Section 10 of the Industrial Disputes Act, 1947, on the ground that the respondent was not a "workman"?
Whether the High Court erred in directing the State Government to make a reference despite the administrative nature of its decision under the Act?
RULE:
The determination under Section 10 of the Industrial Disputes Act is an administrative act requiring the Government’s subjective satisfaction based on material before it. Courts cannot scrutinize this decision as if it were a judicial or quasi-judicial determination. However, if irrelevant or foreign considerations are taken into account, judicial review may be warranted.