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CENTRAL UNIVERSITY OF SOUTH BIHAR

PROJECT
Of
Labour and Industrial Law
Topic: Judicial Delineation of Statutory Definition of Trade
Union and Trade Dispute.

Submitted to: Dr. Ram Chandra Oraon


Submitted by: Kumari Anjali Sinha
Enroll. Id: CUSB1613125026
Program: B.A.LL.B (Hons.)
Semester: 7thsemester
Paper: Labour and Industrial Law (LAW401)

Acknowledgment
1
I would like to express my special thanks of gratitude to my

Dr. Ram Chandra Oroan, who gave me the golden

opportunity to do this wonderful project of Labour and

Industrial Law on the topic “Judicial Delineation of Statutory

Definition of Trade Union and Trade Dispute,” who has

helped me in completing my assignment. I came to know

about so many new things I am really thankful to them.

Secondly I would also like to thank my parents and friends

who helped me a lot in finalizing this project within the

limited time frame.

Kumari Anjali Sinha


B.A.LL.B, 7th Semester

2
Table of Contents

Sr.no Contents Page no.


1. Table of cases 04
2. Introduction 05
3. the definition 06 - 08
4. members of the trade union 09- 13
5. trade or industry 14 - 16
6. objective of trade union 17
7. trade dispute 18
8. Conclusion 19
9. Bibliography 20

table of cases

3
 Panyam Cement Employees Union v. Commissioner of Labour
 Radhakishan Jaikishan Ginning and Pressing Factory v. Jimnadas Nursery
Ginning and Pressing Co. Ltd
 Western India Automobile Association Ltd v. Industrial Tribunal
 Government Tool Room and Training Centre's Supervisors and officers
Association v. Assistant Labour Commissioner
 Rangaswami v. Registrar of Trade Unions
 T T Devasthanam v. Commisioner of Labour
 C M T Institute v. Mihir Kumar Gooha
 Registrar of Trade Unions v. Mihir Kumar Gooha
 Registrar of Trade Unions v. M Mariswami
 Registrar of Trade Unions v. Fire Service Workers Union
 CMT Institute v. Assistant Labour Commissioner
 Registrar of Trade Unions v. Fire Service Workers Union

Introduction
Trade union is a voluntary organization of workers relating to a specific trade, industry or a
company and formed to help and protect their interests and welfare by collective action. In
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other word A Trade Union is an organisation of workers, acting collectively, who seek to
protect and promote their mutual interests through collective bargaining Trade union are the
most suitable organisations for balancing and improving the relations between the employees
and the employer. They are formed not only to cater to the workers' demand, but also for
imparting discipline and inculcating in them the sense of responsibility. Trade union, also
called labour union, association of workers in a particular trade, industry, or company
created for the purpose of securing improvements in pay, benefits, working conditions, or
social and political status through collective bargaining.

Trade dispute “means any dispute between employers and workers which is connected
with the employment or non-employment, or the terms or conditions of or affecting the
employment, of any person”. Trade dispute' means any dispute between employers and
workmen, or between workmen and workmen, which his connected with the employment or
non-employment or the terms of the employment, or with the conditions of labour, of any
person, and the expression 'workmen' means all persons employed in trade or industry
whether or not in the employment of the employer with whom a trade dispute arises.

The Definition
A trade union for an average man signifies an association of workers which is engaged in
securing certain economic benefits for its members. A trade union may also try to advance

5
the social, political and cultural interests of its members through collective action. A Trade
Union is commonly regarded as an association to help its members in getting collectively
better terms of employment, wages, etc. The legal definition of a trade union, however,
permits even employers' organisations to get themselves registered as trade unions.

Sidney and Beatrice Webbs have defined a trade union as "A continuous association of wage
earners for the purpose of maintaining or improving the conditions of their working lives".

Professor Dhyani has rightly remarked that when Webbs wrote their classic work in 1894 and
defined trade union as above, this definition was correct. However, after First World War the
nature, scope, and philosophy of trade unions have undergone a change encompassing every
phase of human activity. In India, as in England and United States Trade Unions not only
resorted to large scale strikes for seeking economic concessions for their members but also
actively aligned with the political groups or parties outside their sphere with a view to have
representation in the legislative bodies. Webb's definition of Trade Union does not include
the association of employers and of white collar employees which are generally regarded by
English and Indian law as trade unions. But in the popular sense of the term the definition of
trade union given by Webbs is still valid. Trade Unions, as generally, understood, are
combination of workmen of same trade or of several allied trades for the purpose of securing
by united action, the most favourable conditions as regards wages, hours of labour, etc., for
its members. The essence of trade union is found in the solidarity among its rank and file as a
security against the right of hire and fire of the employers.

In fact, Trade Unions are voluntary organisations of workers formed to promote and protect
their interests by collective action. A Trade Union “must possess definite aims, itsmembers
must be welded together in a united front for the good of the whole group rather than for the
promotion of any selfish, individual interests; and it must, to be effective, take on a definite
and permanent form of organisation through which it strives to accomplish its goals.”

In fact strength lies the unity. It functions effectively on the solemn belief that 'united we
stand and divided we fall'. Therefore, the workers must be organised, united for collective
action and they must intend to serve common interest and should not work with the selfish
motives. The Trade Unions may be effective and powerful only when their trade union is
made on the permanent basis. The temporary association may not be able to succeed to
accomplish its goals and objectives.

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We may conclude that trade union as commonly understood is a voluntary association of
workers constituted for promoting, advancing and protecting their interests by means of
united action formed with a view to secure maximum benefits, rights, privileges and welfare
of the labour class1.

Until 1926, no legislative attempt was made in India to delineate the contours of the
expression ‘trade union' or any of its synonyms. In 1926, Section 2(h) of the Trade Unions
Act, 1926, inter alia, defines a "Trade Union' to mean: Any combination, whether temporary
or permanent, formed primarily for the purpose of regulating the relations between workmen
and employers or between workmen and workmen, or between employers and employers, or
for imposing restrictive conditions on the conduct of any trade or business, and includes any
federation of two or more trade unions.

The dimensions of the aforesaid definition determine the permissible area of trade union
activities. An analysis of the above definition reveals that a trade union:

(i) must be a combination;


(ii) such a combination should be either temporary or permanent and
(iii) Should include any federation of two or more trade unions.

Further, the definition recognizes that the objectives under its constitution are one or more of
the following:

(a) To regulate the relations:

(i) Between workmen and employers;

(ii) Among workmen; or

(iii) Among employers;

(b) To impose restrictive conditions on the conduct of any trade or business. But it shall not
affect:

(i) An agreement between parties as to their own business;

(ii) Agreement as to employment;

1
Goswami. V.G, labour and industrial law, allhabad central law agency, 10 th edition 2015, pg. 836.

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(iii) Agreement in consideration of sale of the goodwill of a business or profession, trade or
handicraft2.

A delineation of the nature of trade unions requires description of:

(1) The person who can become member of a trade union;

(2) The place in relation to which trade unions are formed; and

(3) The objectives of trade union3.

The analysis of the definition of the trade union clearly shows that the purpose of trade union
is to maintain balance, harmony and proper adjustments in the relations of the persons
involved in industrial process and production. The purpose of the trade union is not to secure
harmony between the employers and workmen only but it is intended to secure peaceful
relations between workmen and workmen and between employers and employer also. In the
definition of Trade Union the regulation of relationship contemplated is in regard to the
conditions of service of the employees which postulates the existence of an employer who is
concerned with the business, trade or industry Another primary object of the Trade Union is
the imposition of restrictive conditions on the conduct of any trade or business of its
members. However, the use of the word 'primarily in the Trade Union Act suggests that trade
unions can have other secondary objectives as well. A trade union may provide for other
objectives also and it cannot be refused registration simply on this ground. As long as the
primary objectives are those that are mentioned in the Act, any trade union can claim
registration in spite of certain secondary objectives in ts constitution. All at we can say is that
the secondary and ancillary objectives should not be inconsistent with the primary objects.
These objects, of course, must not be opposed to any law of opposed to public policy.

Member of the Trade Union


The Trade Unions Act, 1926, does not specifically provide persons who may be a member of
a trade union. However, the regulations framed under the Trade Unions Act, 19263 make it
clear that the trade union may either be formed by workmen or employees. Section 2(h) of
2
Proviso to section 2(h) of the Trade Union Act, 1926.
3
Mishra. S. N, labour and industrial laws, allhabad central law publication, pg. 513.

8
the Act and other provisions also confirm this view. It is therefore, necessary to delineate the
contours of the expression 'workmen' and employers'.

Workmen

In the traditional sense, trade union is used to denote the union of workmen. Further, the
workmen constitute the major part of a trade union. It is, therefore, necessary to ascertain its
meaning. The term 'workmen' has not been independently defined in the Trade Unions Act.
But in the definition of the term "trade dispute in Section 2(g), the definition of the term
'workmen are found which says: All persons employed in the trade or industry whether or not
in the employment of the employer with whom the trade disputes arise. Broadly speaking,
workmen must be:

(a) persons;

(b) employed;

(c) in any trade or industry:

(d) to do work.

The definition of the term workmen however raises various problems:

First, whether the persons other than those who are employed to do any skilled or unskilled,
manual, supervisory, technical or clerical work may be covered within the meaning of the
word 'workmen'?

Second, whether the 'workmen may be persons:

(a) Who are subjected to Army, Air Force or Navy Act; or

(b) Who are employed in the police service or IAS officer or other employees of a prison; or

(c) who are employed mainly in a managerial or administrative capacity or exercise functions
mainly of managerial 'nature'?

Third, whether the gratuitous workers may indulge trade?

Fourth, whether there should be a contract of employment between 'employers and


'workmen'?

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Fifth, whether there is any age restriction for becoming a member of a trade union?

Sixth, whether badli workers are workmen?

Seventh can the dismissed, discharged, or retrenched worker become member of a trade
union?

As to the first, it is significant to note that the term ‘workman’ defined in the Trade Unions
Act, 1926 has a wide coverage and is not merely confined to only those persons who are
employed to do any manual, skilled, unskilled supervisory, technical, operational or clerical
work. In other words, all persons employed to do any kind of work may be covered within
the definition of workmen' provided they are employed in any trade or industry.

The second problem may conveniently be divided in two categories. The employees of the
first category, namely: (i) those who are subject to the Army, Air Force and Navy Act or (ii)
those who are employed in the police service or as officers or other employees of a prison are
not covered within the meaning of the term 'workmen because they are not employed in the
trade or industry. The employees of the second category, namely:(i) those who are employed
mainly in the managerial or administrative capacity; or (ii) those who are employed in the
supervisory capacity exercising functions mainly of managerial nature may conveniently be
brought within the preview of 'workmen provided they are employed in any 'trade' or
'industry.

As to the third problem, it may be said that the definition of 'workmen covers even gratuitous
workers. It may, therefore, be possible for them under the Trade Unions Act, 1926 to be
members of a trade union.

The fourth problem requires careful scrutiny. According to the definition, it is not necessary
that there should be a contract of employment between the employer and workmen. Indeed,
the courts emphasize that an employee does not cease to be an 'employee merely because he
is employed through intermediaries4.

Section 21 A (1) (i) of the Trade Unions Act, 1926 sheds sufficient light on the fifth problem.
It, inter alia, provides that a person, who has attained the age of 15 years, may be a member
of registered trade unions unless the rules of trade unions provide otherwise. But a person

4
Shrivastava. S.C, Industrial relation and labour laws, New Delhi Vikash Publishing company, pg.152.

10
who has not attained the age of 18 years can neither be an office-bearer of any such trade
union nor can he be chosen a member of the executive of the unions5.

Formation of Trade Union by Badli Worker

As to the sixth problem, the Andhra Pradesh High Court in Panyam Cement Employees
Union v. Commissioner of Labour6 held that badli workmen are workmen and, therefore, if
management disapproves of a trade union of badly workers or discourages badli workers to
join a trade union or denies voting right to badli workers, the same would amount to unfair
labour practice.

The last problem requires due consideration. The definition unlike the Industrial Disputes
Act, 1947, does not specifically include the dismissed, discharged, or retrenched workers in
its fold. Indeed, the use of the expression 'employed in the trade or industry' occurring in
Section 2(g) of the Act and the expression 'union of workers engaged in industry occurring in
Form A of the Central Trade Unions Regulation, 1938, make it highly doubtful whether the
dismissed, discharged or retrenched workmen may be covered in the definition of 'workmen.

It has been observed in Radhakishan Jaikishan Ginning and Pressing Factory v.


Jimnadas Nursery Ginning and Pressing Co. Ltd 7., that the definition brings under the
term trade union not only combination of workmen, but also combination of employers such
as employers' federation (or union of employers) or a combination of employers in any
industry, imposing restrictions on the members in respect of prices to be charged from the
customers, since one of the principal objects of the latter is to regulate the relations between
employers. The Trade Unions Act, 1926 therefore, applies to employers federation as it does
to unions of workmen. It is, therefore, essential to know its coverage. The Trade Unions Act,
1926, does not define the term 'employer. However, Section 2(g) of the Industrial Disputes
Act, 1947, defines an 'employer’ to mean:

(i) in relation to an industry carried on by or under the authority of any department of


the Central Government or a state government, the authority prescribed in this
behalf, or where no authority is prescribed, the head of the department;
(ii) (ii) in relation to an industry carried on by or on behalf of a local authority, the
chief executive officer of that authority.

5
Section 21A.
6
(2001) 1 LLJ 915
7
AIR 1940 Nagpur, 228.

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In Western India Automobile Association Ltd v. Industrial Tribunal 8, the Federal Court
held that statutory definition is not exhaustive. Observed Justice Mahajan:

“In relation to industries carried on by government or local authorities only a definition has
been given of the term 'employer No attempt, however, was made to define the term
'employer generally or in relation to other persons carrying on industry or running
undertakings. The proposition has since been not challenged though, paradoxically, the
provisions of the Industrial Disputes Act, 1947, have never been invoked to the industrial
disputes arising in 'an industry carried on by or under the authority of any department of the
Central or a State Government”.

An Employer does not cease to be an 'employer merely because instead of employing


workmen himself, he authorizes his agent or servant to employ them. However, in view of the
provisions of Section 18 of the Industrial Disputes Act, 1947, the coverage of the expression
'employer has been extended to include his heirs, successors, and assignees.

Formation of a Trade Union by Supervisions and Managers

Can the supervisory officers and managers form a trade union under the Trade Unions Act?
This question arose in Government Tool Room and Training Centre's Supervisors and
officers Association v. Assistant Labour Commissioner9. In order to deal with the issue,
the court referred to the provisions of Section 2(g) of the Trade Unions Act which defines
trade dispute to mean any dispute between employers and workmen or between workmen and
workmen, or between employers and employers which is connected with the employment or
unemployment or the terms of employment or the conditions of labour, of any person and
'workmen means all persons employed in trade or industry whether or not in the employment
of the employer with whom the trade dispute arises.

It also referred to the provisions of Section 2(h) of the Trade Unions Act which defines 'trade
union to mean any combination, whether temporary or permanent, formed primarily for the
purpose of regulating the relations between the workmen and employers or between workmen
and workmen, or between employers and employers, or for imposing restrictive conditions on
the conduct of any trade or business and includes any federation of two or more trade unions.
While interpreting the scope of the aforesaid two definitions, the Karnataka High Court
observed that the word ‘workmen’ under the Trade Unions Act includes all persons employed
8
(1949) LLJ 245 (FC)
9
(2002) Lab. IC 103

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in a trade or industry. It is not a restricted definition as in any other enactment of labour laws.
When the Act itself provides for wider definition and for a wider meaning, the court cannot
narrow it down by its decision. That would be against the very object of the Trade Unions
Act itself. The court added that it is a well-settled principle of law that two conditions are
necessary for interpreting an earlier enactment in the light of the provisions of a later Act.
They are: (i) the two Acts of the legislature must be in, pari materia, that is to say that they
form a system or code of legislature; and (ii) the provisions in the earlier Act are ambiguous.

Trade or Industry
After having discussed as to who may become the members of a trade union, it is necessary
to determine the area in which the trade unions operate. The arena of interaction of trade
union is "trade or industry. The Trade Unions Act, 1926, however, does not spell out either

13
the term trade' or 'industry. A question, therefore, arises whether the Trade Unions Act, 1926
is in pari materia with the Industrial Disputes Act, 1947. The Madras High Court in case of
Rangaswami v. Registrar of Trade Unions 10 has answered it in negative because in its
view, a comprehensive meaning of the term 'industry was considered by the legislature in
regard to the Industrial Disputes Act. On the other hand, the Andhra Pradesh in case of T T
Devasthanam v. Commisioner of Labour11 and Karnataka High Courts in case of C M T
Institute v. Mihir Kumar Gooha12 have taken the view that two enactments are in pari
materia and that the expression 'trade or industry in Section 2(g) of the Trade Unions Act
carries the same meaning as the word 'industry in Section 2 (j) of the Industrial Disputes Act.
There is, however, no decision of the Supreme Court on this point. Section 2 (j) of the
Industrial Disputes Act, 1947, however, defines the tem, 'Industry to mean:

“any business, trade, undertaking, manufacture or calling of employers and includes any
calling services, employment, handicraft, or industrial occupation or avocation of workmen.”

The words used in the above definition are of very 'wide import’. It will be observed that the
word 'industry is wide enough to include 'trade in its ambit. It will be further noticed that the
definition is in two parts. The first part defines 'industry with reference to employers and the
other part defines it with reference to workers. The words occurring in the definition are
vague and have given rise to several disputes. Courts and tribunals have, therefore, been
called upon to interpret and apply the key expression on innumerable occasions.

Registrar of Trade Unions v. Mihir Kumar Gooha 13. In this case a question arose whether
employees of Employees' State Insurance Corporation could form a 'trade union under the
Trade Unions Act. The Registrar on an application made by the employees for registration
first registered it but later cancelled its registration. Against the latter order of cancellation, an
appeal was filed before the appellate court. The court set aside the order of the registrar
cancelling the certificate of registration. Against this decision they preferred a Letters Patent
Appeal before the division bench of the Calcutta High Court. The Division Bench, upholding
the order of the single judge, observed: In my opinion, this test may well be applied the
expression industry as also 'trade or 'business as used in the Trade Unions Act. In this Act
also profit motive is not essential and providing amenities or services to the community or a

10
AIR 1962 Madras 231.
11
(1979) 1 LLJ 448
12
(1979) 1 LLJ 192
13
AIR 1963, cal 56

14
substantial portion of it would be sufficient to satisfy the test. The fact that such services are
to be rendered by a statutory corporation makes no difference. The fact that a large number of
employees are employed by an employer, to render services for particular class of persons in
an organized manner is quite sufficient to bring the corporation within the mischief of the
Act. The employees of such a corporation are, 'workmen as defined in Section 2 (g) of the
Trade Unions Act and are entitled to form a trade union and get it registered. The Court
added the learned judge below had come to the right conclusion and rightly set aside the
order of cancellation passed by the registrar of trade unions.

Registrar of Trade Unions v. M Mariswami14. In this case, the employees of the Provident
Fund Organization made an application to the registrar of trade unions for the registration of
its trade union called the Mysore State Provident Fund Employees Union under the Trade
Unions Act, 1926. The registrar of trade unions first issued a certificate of registration but
later, after issuing a show cause notice, withdrew its registration certificate. On appeal, the
district court allowed the appeal and set aside the order of the registrar. In a revision petition
against the order of the district court, the High Court observed:

...As the activity of the Provident Fund Organization is 'industry', the members of the union,
who are its employees have to be regarded as workmen. As the union was formed primarily
for the purpose of regulating the relations between the workmen and its employer, it is a trade
union as defined in Section 2(h) of the Act.

Registrar of Trade Unions v. Fire Service Workers Union15. In this case, the employees of
the Fire Brigade Services formed a union and applied for its registration to the registrar of
trade unions. The registrar first registered the union but later cancelled the certificate of
registration after giving the notice. Against this order, the union filed an appeal to the High
Court. The High Court held that employees employed in Fire Brigade Services were
employed in trade or industry' and were entitled to be registered under the Trade Unions Act,
1926.

The Karnataka High Court in CMT Institute v. Assistant Labour Commissioner 16,
(1979) 1 LL 192 applied and extended the definition of 'industry under the Industrial
Disputes Act, 1947 in interpreting the word trade or industry' occurring in section 2(g) of the
Trade Unions Act, 1926. The Court also pointed out that there was no difference between the
14
(1973) 2 LLJ 256
15
(1963) 1 LLJ 167
16
(1979) 1 LLJ 192

15
meaning of the word 'industry as defined in section 2() of the Industrial Disputes Act and the
word 'trade or industry as used under section 2(g) of the Trade Unions Act. The Court also
held that the word "trade or industry even without elaborate definition of the word 'industry
under the Industrial Disputes Act, was sufficiently wide enough to bring the Society of
Central Machine Tool Institute within the definition of trade or industry notwithstanding the
fact that it had no profit motive.

An analysis of judicial response relating to the Trade Unions Act, 1926, reveals that the
several organizations such as Employees' State Insurance Corporation, Provident Fund
Organization, Fire Brigade Service, Devasthanam, CMT Institute have been held to be trade
or industry under Section 2) of the Industrial Disputes Act, 1947 and the Trade Unions Act,
1926.

Registrar of Trade Unions v. Fire Service Workers Union. In this case, the employees of
the Fire Brigade Services formed a union and applied for its registration to the registrar of
trade unions. The registrar first registered the union but later cancelled the certificate of
registration after giving the notice. Against this order, the union filed an appeal to the High
Court. The High Court held that employees employed in Fire Brigade Services were
employed in trade or industry' and were entitled to be registered under the Trade Unions Act,
1926

On the other hand, persons employed in the following are not employed in 'industry, e. g.,
Raj Bhawan, educational institutions run by Ramakrishna Mission, Pasteur Institute of
Southern India and the Council of Scientific and Industrial Research, sovereign or legal
functions of the state and a temple managed by trustee of a Devaswom governed by the
Hindu Religious and Charitable Endowment Act, 1951.

Objective of Trade Union


The Trade Unions Act, 1926 prescribes the primary objectives of a trade union.

The objectives are one or more of the following:

(a) To regulate the relations:

(i) Between employers;

16
(ii) Among workmen; or

(iii) Between employers and workmen

(b) To impose restrictive conditions on the conduct of any trade or business17.

The objective for which the trade union is formed complies with the aforesaid primary
objects. In other words, the primary objects of trade unions determine whether the union is a
trade union under the Act. The statutory provisions 'for only primary objectives in the Act,
however, suggests that there may be some objectives other than the primary objectives of
trade unions. These objectives may be broadly categorized as follows:

(i) Economic objectives;

(ii) Political objectives; and

(iii) Social and welfare objectives. This view is fortified by the provisions of section 15 of the
Act.

Trade Dispute
The expression trade dispute means any dispute between employers and workmen or between
workmen and workmen or between employers and employers which is connected with the
employment or non-employment or the terms of employment or the conditions of labour of
any person, and 'workmen' means all persons employed in trade or industry, whether or not in
the employment of the employer with whom the trade dispute arises.

17
www.legalserviceindia.com//-456-labour law, last visited on 25th october 2019.

17
Trade dispute is defined in Section 2(g) of the Trade Unions Act, 1926 to mean:

“any dispute between employers and workmen, or between workmen and workmen, or
between employers and employers which is connected with the employment or non-
employment, or the terms of employment or the conditions of labour, of any person, and
'workmen' means all persons employed in trade or industry whether or not in the employment
of the employer with whom the trade dispute arises18”

Reading the definitions of trade union' and trade dispute it is evident that any dispute, inter
alia, between the employer and workmen connected with the employment or non-
employment, terms of employment or conditions of labour of any person would be a trade
dispute and the term ‘workman’ includes all persons employed in the trade or industry. Any
dispute between badli workers and the management is also a trade dispute. It is for this reason
that when there was a settlement between the Mazdoor Union and Panyam Cement Co. In
June, 2000, both the parties agreed on certain terms regarding assured employment to badli
workers. In that view of the matter, badli workers cannot be excluded from participating in
the election recognize the majority trade union. Any other interpretation would lead to badly
workers to lurch in helpless state of suspended animation19.

Conclusion
Labour unions or trade unions are organizations formed by workers from related fields that
work for the common interest of its members. They help workers in issues like fairness of
pay, good working environment, hours of work and benefits. They represent a cluster of
workers and provide a link between the management and workers. The purpose of these
unions is to look into the grievances of wagers and present a collective voice in front of the

18
www.legalbite.com// trade dispute last visited on 21st october 2019
19
Panyan Cement Employees Union v. Commissioner of Labour, Hyderabad, (2004) 1 LLJ 915

18
management. Hence, it acts as the medium of communication between the workers and
management. Regulation of relations, settlement of grievances, raising new demands on
behalf of workers, collective bargaining, and negotiations are the other key principle
functions that these trade unions perform. Any dispute between employers and workmen or
between workmen and workmen, or between employers and employers which is connected
with the employment or non-employment, or the terms of employment or the conditions of
labour, of any person, and 'workmen' means all persons employed in trade or industry
whether or not in the employment of the employer with whom the trade dispute arises.

Bibliography
BOOKS

 V G GOSWAMI, LABOUR AND INDUSTRIAL LAW, ALLAHABAD


CENTRAL LAW AGENCY.

19
 S C SHRIVASTAVA, INDUSTRIAL RELATION AND LABOUR LAWS, NEW
DELHI VIKAS PUBLISHING COMPANY.
 S N MISHRA, LABOUR AND INDUSTRIAL LAW, ALLHABAD CENTRAL
LAW PUBLICATION.

WEBSITE

 WWW.LEGALSERVICEINDIA.COM
 WWW.LEGALBITE.COM
 WWW.INDIANKANOON.COM

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