ISSUE:
Whether a dispute regarding the employment or non-employment of a person who is not classified as a "workman" under Section 2(s) of the Industrial Disputes Act, 1947, an industrial dispute under Section 2(k) of the Act?
Whether a dispute qualifies as an industrial dispute under the Act based on direct or substantial interest of the party raising the issue, and what separates a collective dispute from an individual argument in the context of industrial disputes?
RULE:
For a dispute to qualify as an industrial dispute under Section 2(k), the workmen involved must have a direct or substantial interest in the employment or conditions of labor of the individual concerned.
This criterion excludes individuals in positions like managerial or medical staff, whose employment status generally does not affect the workmen’s direct employment interests or conditions of labor.