ALIGARH MUSLIM UNIVERSITY

MALAPPURAM CENTER
2021-22

LABOUR LAW
PROJECT

TOPIC:- RETRENCHMENT AND LAY-OFFs

SUBMITTED TO SUBMITTED BY:

ADV. MTA SALAAM SURYA GAUTAM
DEPARTMENT OF LAW 18BALLB043
AMU MC GH4185
 

INDEX 

PAGE
NO..
NO TOPI
TOPIC-
C- RE
RETR
TREN
ENCH
CHME
MENT
NT
NO.

1.   Retrenchment, Definition,
Definition, for any reason
reason whatsoever, cases   3

2.   Impact of 1984 amendment, termination

termination of casual
casual workers   5

3.   Retrenchm
Retrenchment
ent can be only in a live industry,
industry, closur
closure
e should be real   6

4.   Termination not as punishment, Exclusion

Exclusion from the
the definition of retrenchment
retrenchment   6

5.   Condition for
for valid retrenchment, notice
notice mandatory, retrenchment compensation
compensation   7

6.   Rate of compensation,
compensation, Notice to appropriate
appropriate Government
Government   9

7.   Reme
Remedy
dy - violation of sec 25-F, Impact
Impact of 1976 & 1984 amendment
amendment   10

8.   Retrenchment procedure, last come first go,   12

9.   Depa
Departure
rture from
from the rule ‘last
‘last come first
first go’    13

10.  Re-employment of retrenched workman – Section 25-H & Conditions   14

11.  Sec 25-H only prospective, not applicable for closure or transfer   15

12.  Retrenchment compensation on transfer of undertaking- scope, background   16

13.  Condition to be fulfilled to be entitled for compensation,   17

14.  Obligation to pay compensation,   18

15.  When Sec 25-FF right are not available,  Retrenchment attracts Sec 25-F ,   19

16.  Closure Notice, Compensation in case of closure of undertaking – Sec 25-FFF   20

17.  Sec 25-FFF Infringes Art 14 And 19(1)(g), Closure differs from retrenchment,   21

18.  Distinction between lay-off and retrenchment   23

19.   Conclusion   24

20.   Bibliography   25

2
 

RETRENCHMENT

Retrenchment is a permanent measure to remove surplus staff because of some

 basic change in the nature of the business. It results in a complete severance of employer-

employee relationship. It is a case of involuntary unemployment to the workman. Until

1953 there was no statutory provision in India to give immunity or protection from the

risk of such involuntary unemployment. In 1953 some provisions were incorporated in

the Industrial Disputes Act and in 1976 some more amendments were introduced.

Definition-section 2(OO) of the Act defines retrenchment as ter m

mination
ination by the employer 

of the service of a wo
w orkman for any reason whatsoever, otherwise than as punishment

inflicted by way of dis

disciplinary action. But it does not include  (a)  voluntary retirement of 

the workman;   (b)  retirement on reaching the age of superannuation;  (bb)1 termination of 

the service of the workman as a result of the non-renewal of the contract of employment

 between the employer and the workman concerned on the expiry of th

thee  contract being

terminated under a stipulation contained therein; or   (c)  termination of ser v

vices
ices on ground

of continued ill health2.

“For
“For any
any re
reas
ason
onss what
whatso
soev
ever”:   In   Sundarma
er”: ny’s case3 th
Sundarmany’s thee ba
bank
nk,, empl
employ
oyed
ed

respondent as a temporary employee because the permanent cashier was away. When the

 permanent cashier joined duty, Sundarmany’s services were dispensed with. The High

Court held this was nothing but discharge of Sundarmany as surplus employee. The bank 

appealed before the Supreme Court and Justice Krishna Iyer gave a very wide content to

the definition of retrenchment. The words “for any reason whatsoever” was interpreted to

mean whatsoever be the reason every termination spells retrenchment. The Court

1 Added by the 1984 amendment.

2
K.M. Pillai – Labour and Industrial Laws 11 th Edition 2007 pg 164
3
State Bank of India v Sundarmany AIR 1976 SC III;

3
 

observed that had the bank known the laws, half a month’s pay would have concluded the

story and the bank was order

ordered
ed to reinstatemen
reinstatementt the employee.

In  Hindustan Steel case, the workmen were timekeepers for a number of years on the

fixed term. Their services have been extended from time to time. Later ,  consistent with

the economic policy, the employer chose not to renew the contract. The Supreme Court

held that such termination is retrenchment falling within Sundarmany’s case. The Court

discussed the impact of a composite order which implied the single order covering an

appointment and termination of services. In cases of composite order the absence of an

independent order terminating the services will not affect the coverage of retrenchment.

Abovee decisions
Abov decisions were reiterated in Delhi Cloth & General Mills v Sambu Nath 4,  which
reiterated

held that striking off the name of a workman

workman from the rolls amounted
amounted to retren
retrenchment
chment..

In  Santosh Gupta v State Bank of India 19805, the appointment of an employee of the

Bank in 1973 was terminated after a year in 1974 on the ground that she did not pass the

test which would have enabled her to be confirmed in the service. The Supreme Court

held
held this
this as re
retre
trenc
nchm
hmen
entt un
unde
derr se
secti
ction
on 25
25-F
-F.. The
The mana
manage
gemen
mentt co
cont
nten
ende
ded
d   tha
hatt th
thee

termination was not due to discharge of surplus labour and therefore, section 25-F and

section 2(OO) would not attract. Rejecting this argument the court observed that section
2(OO) is so comprehensive to cover termination for any reason whatsoever except those

not expressly included in section 25-F or not expressly approved for by other provisions

of the Act such as section 25-FFF. The object of the above provisions is to compensate

the workman for loss of employment, until he finds alternate employment 6.

4
AIR 1978 SC 8
5
Santosh Gupta v State Bank of India 1980, Lab IC 87 (SC)
6
Indian Hume Pipe Co v Workmen, AIR 1960 SC 251

4
 

Impact of 1984 amendment  : However, after the insertion of section 2(OO) (bb) in 1984,

the
the ab
abov
ovee posit
positio
ion
n su
subs
bstan
tantia
tially
lly ch
chan
ange
ged.
d. Henc
Hence,
e, when
when th
thee empl
employ
oymen
mentt wa
wass for
for a

st
stip
ipul
ulat
ated
ed time
time pe
peri
riod
od un
unde
derr a cont
contra
ract
ct th
then
en th
thee no
non-
n-re
rene
newa
wall of th
thee cont
contra
ract
ct of 

employment on the expiry of the stipulated period would not amount to retrenchment.

Pr
Proba
obatio
tioner
ner entit
entitled benefitt- In   Karna
led to benefi Karnata
taka
ka S.R.
S.R.T
T Corp
Corpn.
n. V. Sh
Shei
eikh
kh Abdu
Abdull

Khaddar7,   the Supreme Court held that disc

discharge from employment or termination of 

serv
servic
icee of a prob
probat
atio
ione
nerr also
also amou
amount
nt to re
retre
trenc
nchm
hmen
ent.
t. As such
such wh
while
ile di
disch
schar
argi
ging
ng a

 probationer if the requirements of section 25-F had not been complied with, the same is

void. Workers engaged only during crushing season in a sugar factory were ceased to

work subsequent
subsequent to closur
closuree of the season will not attract retrenchment.
retrenchment.

Termination of casual worker’s service is not retrenchment   -Termination of casual

worker engaged for particular urgent work on completion of such work will not amount to

retrenchment. Where the workman was engaged on casual basis without a written service

cont
contra
ract
ct or lette
letterr of ap
appo
poin
intm
tmen
ent,
t, fo
forr do
doin
ing
g a pa
part
rticu
icular
lar ur
urge
gent
nt work
work,, hi
hiss servi
service
ce

automatically came to an end when the work was over and there was no retrenchment.

Therefore, the question of complying with the procedure for retrenchment does not arise

in such case. Further, in such a case merely because the workman was required repeatedly

for doing the urgent work and thus had to work for considerable time, the termination of 

servic
servicee would not amount
amount to retrenc
retrenchment8. Un
hment Unli
like
ke in   Sundarmany’s   case
case or in the

 Hindustan Steel Ltd  case

  case where the contract of employment was for a specific period that

came to an end by efflux of time in terms of the agreement between the parties, the

context
context and facts in the instant case are quite differen
different.
t.

7 AIR 1983 SC 1320

8
Marinda Cooperative Sugar Mills v Ramkishen AIR 1996 SC 332

5
 

Retrenchment can be only in a live industry  - Since the termination of the services of a

workman who is employed in an industry constitutes retrenchment, it clearly indicates,

that there must be an “industry” which must be running or in existence. It required an

industry which is alive and not closed. As in the case of strike, lock-out or lay-off there

retrenchmentt in a closed or dead industry9.

cannott be a retrenchmen
canno

Closur
Closuree should reall- Clo
should be rea Closu
sure
re shou
should
ld no
nott be mere
mere pr
pret
eten
ence
ce or cl
cloa
oak
k to av
avoi
oid
d th
thee

liability of a retrenchment. “If there is no real closure, but a mere pretence of a closure or 

it is a mala fide one there is no closure in the eye of law and the workmen can raise an

industrial dispute”. Where there has been closure or not is a question of fact and once it is

 proved that there is real and factual closure the bona fide or mala fides behind it   is

immaterial
immaterial to the fact of closure.

Termin
Terminat
ation
ion not as punish
punishment- Term
ment Termin
inat
atio
ion
n of th
thee se
serv
rvic
ices
es of a work
workma
man
n as

 punishment inflicted by way of disciplinary action will not be a retrenchment. The facts

of the case are to be considered whether a particular termination is a retrenchment or by

way of disciplinary action. Hence, the termination of services on ground of misconduct 10,

ill health and inefficiency of the work

workmen
men are declared
declared to be not retrenchmen
retrenchment.
t.

Exclusion from the definition of retrenchment-

a) Volunt
Voluntary
ary retir
retirement- Being an act of the employee in terminating the services by
ement

abandoning or resigning from the service such as voluntary retirement will not be

covered by the definition.

b) Sup
Super
erann
annuation-To attract termination of service on superann
uation superannuation
uation it is necessary

that:-

9
Union of India v Pitu Kishu (1977) I Lab IC 1236 (Cal)
10
Imperial Tobacco Co. v Ethiraj (1954) II LLJ 637 (Lat)

6
 

i) There must be stipul

stipulation
ation on the point of retrenchmen
retrenchmentt in the contra
contract
ct of 

employment between the employer and employee; and

ii) The stipula

stipulation
tion must be with regard to the age of superannuation.
superannuation.

Termin
Terminatio
ation
n of service
service on sati
satisfac
sfactio
tion
n of these
these two con
conditi
ditions
ons will
will not con
constit
stitute
ute

re
retr
trenc
enchm
hmen
ent.
t. Bu
Butt if such
such ag
agee of su
supe
pera
rann
nnua
uatio
tion
n is no
nott ment
mentio
ione
ned
d ei
eith
ther
er in th
thee

cont
contra
ract
ct of empl
employ
oyme
ment
nt or in
inva
vali
lid
d stan
standi
ding
ng or
orde
ders
rs,, it wi
will
ll no
nott be trea
treate
ted
d as

termination on superannuation under this clause11.

c)   Ter
Termin
minat
ation
ion on non
non-r
-rene
enewal
wal of servic
servicee contr
contrac
actt or on exp
expiry
iry of fixed
fixed te
term
rm

contract - When the employment was for a stipulated time period under a contract

then the non-renewal of the contract of employment on the expiry of the stipulated

 period would not amount to retrenchment12.

13
d) Contin
Continued
ued ill health -Termination owing to the continued ill health of the workman is
health

not covered in retrenchment. Ill health contemplated not only physical but mental

ill health as well. ‘C

‘Continu
ontinued
ed ill hea
health
lth’’ includ
includes
es any physical
physical defect
defect or infirm
infirmity
ity

inc
incapa
apacita
citating
ting a work 
work man
m an fo
forr fu
futu
ture
re work
work fo
forr an in
inde
defin
finite
ite pe
perio
riod.
d. The
The quest
questio
ion
n

whether a workman is suffering continued

continued ill health is a question of fact which may

 be proved or disproved on eit

either
her si
side.
de.

Conditions for valid retrenchment-

of a workman in an industry having continuous ser v
vice
ice of not less than one year 

i) He is given
given one mont
month’
h’ss noti
notice
ce of it wi
with
th reaso
reasons
ns,, or on
onee mont
month
h wag
wages
es in lieu of 

su
such
ch no
notic
tice.
e. Prov
Provid
ided
ed no su
such
ch no
notic
ticee is ne
nece
cessa
ssary
ry if it is unde
underr an ag
agree
reeme
ment
nt

specifying
specifying the date of termination
termination of servic
service;
e;

11
J.K.Cotton
J.K.Cotton Spinnin
Spinning
g Mills & Co v State of UP AIR 1990 SC 1808
12
Harmohinder Singh v Kharga Canteen (2001) 5 SCC 540
13
Anand Bihari v Rajasthan St Rd Corpn 1991 Lab IC 494 (SC)

7
 

ii) He is paid com

compensat
pensation
ion equivalen
equivalentt to 15 days ave
average
rage pay for every
every comp
completed
leted

year of company’s service or any part of it exceeding six months; and

iii) Notice is served on the appro

appropriate
priate gov
governmen
ernmentt or on such notifi
notified
ed authority.
authority.

In  Vishwamitra Press v Workmen14, it was held that mere receipt of notice or wages in

lieu of notice period does not mean that the workers voluntarily gave up their service and

so cannot be precluded from questioning the propriety of their discharge.

Notice Mandatory- Notice or wages in lieu of notice under section 25(a) is mandatory.

Failure
Failure to give notice or  wages
 wages in lieu of notice will vitiate the retrenchmen
retrenchment.
t.

Retrenchment Compensation -   Under Section 25-F(b), payment of compensation is a

mandatory condition precedent for the validity and operative effect of the retrenchment.

If the compensation under Section 25-F(b) is not offered within the notice period under 

Sec 25-F(a), such notice though initially valid would become inoperative and void and no

effect could be given to the notice. Notice or wages in lieu of notice under clause (a) of 

Sec 25-F and payment of retrenchment compensation calculated in the manner set out in

clau
clause
se (b)
(b) of Se
Secti
ction
on 25
25-F
-F ar
aree co
cond
nditi
ition
onss pr
prece
ecede
dent
nt fo
forr re
retre
trenc
nchm
hmen
ent.
t. Henc
Hence,
e, th
these
ese

clauses operate as a prohibition against retrenchment until those conditions are fulfilled.

15
In Pramod Jha v. Bihar ,  the Supreme Court highlighted two fold object to Sec 25-F-
(1) a retrenched
retrenched employee
employee must have one month time to search for alternate
alternate job;
(2) the workman must be paid retren
retrenchment
chment compensatio
compensation
n at the time of retrenc
retrenchment
hment so
that once he is retrenched there is no need for him to go to his employer demanding
retrenchment compensation.
In order to be entitled to the compensa
compensation,
tion, the workmen should have put in minimum of 

one year continuous service during a period of twelve calendar months; 190 days work in

the underground mine or 240 days work in other cases.

14
(1952) I LLJ 181
15
(2003) 3 ACE 167

8
 

Rate of compensation. - Under Section 25-F (b), the workman is entitled to 15 days

average pay for every completed year of continuous service, or any part thereof in excess

of six months continuous service. Under the second proviso to Section 25-C the employer 

has right to set off any amount paid to be workman as lay-off compensation during the

 preceding twelve months as against the compensation payable for retrenchment. In case

of death of the workman,

workman, his legal heirs are entitled
entitled to the retrenchm
retrenchment
ent compensation.
compensation.

Compensation by Money Order-   Sendin

Sendingg the retrenchment compensation by Money

Order when the workman refused to accept the payment of compensation is sufficient

compliance of Sec 25-B16.

Payment of Cheque-  Payment of compe

compensatio
nsation
n by cheque will be sufficient provided the

chequee could be cashed before the retrenchment

chequ retrenchment is effected.
effected. But when the cheque towards

the retrenchment compensation was given after the banking hours and thus the cheque

would be cashed only on the next day, it was held that the retrenchment order issued on

the day when the cheque

cheque was given cannot be valid.

Notice
Notice to the appropria
appropriate
te Government-   Sec 25-F (c) lays down the third condition
Government-

namely, to give notice of 

notice  of  the
 the retrenchment to the Government. However, previous notice

to the gov
governmen
ernmentt under section 25-F(C
25-F(C)) is only directo
directory
ry and not mandatory.
mandatory. In  Bombay

Union of Journalists v State of Bombay17,  the Supreme Court held that sec 27-F(a) and

(b) are mandatory whereas under section 25-F(e) previous notice to the government will

not render
render the retrenchm
retrenchment
ent invali
invalid.
d. Notice
Notice under
under Section
Section 25-F
25-F(e)
(e) was only
only to giv
givee

in
info
form
rmat
atio
ion
n to the
the Gove
Govern
rnme
ment
nt so as to ke
keep
ep in
info
form
rmed
ed abou
aboutt th
thee co
cond
ndit
itio
ions
ns of 

employment of different industries within its region.

16
Management of India Compressors Makers Corpn v D D Gupta (1997) Lab IC 694 (Delhi)
17
1964 I LLJ 351 (SC)

9
 

Remedy against violation of Section 25-F:  As the right or obligation dispute pertaining

to Section 25-F cannot be raised straight away in writ proceedings. The Supreme Court

laid down that the remedy provided by way of making a reference under Section 10 of the

Industrial Disputes Act is the exclusive remedy which should be availed of in respect of 

rights and obligations which are the creation of the Industrial Disputes Act itself.

Retrenchment compensation differs from Gratuity-  The device of gratuity is a retiral

 benefit to an employee for his long, continuous service. But retrenchment compensation

is int
intend
ended
ed to give
give relief
relief for the sud
sudden
den and unexpe
unexpecte
cted
d termin
terminatio
ation
n of employ
employment
ment..

Since the contexts and purposes of both of them are not the same, a workman can claim

 both gratuity benefit and retrenchment compensation, provided the gratuity scheme

framed in the establishment concerned does not prevent him for such double benefit 18.

On termination of the services of a temporary employee on ground of surplusage it was

held that he is entitled to both gratuity and retrenchment compensation.

The Imp
Impac
actt of 1976
1976 and 198
1984
4 amendm
amendment
ent on Ret
Retren
renchment- Under Section 25-N
chment 25-N

in
inse
sert
rted
ed by the
the 19
1976
76 amen
amendm
dmen
entt th
thee fo
foll
llow
owin
ing
g cond
condit
itio
ions
ns are
are requ
requir
ired
ed for
for va
valid
lid

retr
retrenc
enchm
hmen
ent,
t, an estab
establis
lishm
hmen
entt empl
employ
oying
ing 100
100 or more
more work
worker
erss on an av
avera
erage
ge pe
per 
r 

working day in the preceding 12 months.

(i) No workm
workman
an employed
employed in such establishmen
establishmentt shall be retrenched who has been in the

company’s continuous service for not less than one year until:-

(a)
(a) The
The work
workma
man
n ha
hass be
been
en gi
given
ven thre
threee mont
months
hs no
notic
ticee in writi
writing
ng statin
stating
g reas
reason
onss for 
for 

retrenchment and the period of notice has expired or the workman has been paid

wages for that notice period;

(b) No such no
notice
tice is required
required if the retren
retrenchment
chment is under
under an agre
agreement
ement which
which specif
specify
y

the date of termin

termination
ation of service;

18
Indian Hume
Hume Pipe Co Ltd v Workmen AIR 1960 SC 251

10
 

(c) The wor

workman
kman has be
been
en paid compensa
compensation
tion equivalen
equivalentt to 15 days ave
average
rage pay fo
for 
r 

every completed year of service or any part thereof in excess of six months; and

(d) Notice in the pre

prescribed
scribed man
manner
ner has been serv
served
ed on the appropriate
appropriate Government
Government

(ii) The appropriate Government on receipt of notice should hold an enquiry after which

it may grant or refuse in writing

writing the permis
permission
sion for retrenchment
retrenchment19.

In case the appropriate Government does not communicate the permission or the refusal

within three
three months
 months from the date of service of notice seeking permission, the workman

is deemed to be validly retrench

retrenched
ed after expiry of three months.

Section 25-N(7) further empowers the appropriate Government to withdraw by order of a

dis
disput
putee involv
involving
ing questio
questions
ns of retrenc
retrenchme
hment
nt as well
well in an establis
establishme
hment
nt covered
covered by

Chapter
Chapter VB pend
pending
ing before a Concil
Conciliate
iate officer or the Central or State Govern
Government,
ment, if the
appropriate Government is of opinion that such retrenchment is not in the interest of 

industrial peace or that such retrenchment is by way of victimization. The Government

has to transfer such dispute to an authority specified by that Government by notification

in the official Gazette. The order passed by such authority is final and binding on the

employer and the workman. Sec 25N(b) being mandatory, if the compensation is found to

 be insufficient, the retrenchment would be void   ab initio   in the absence of bona fide

action of the employer

employer or waiver of the workman.
workman.

Penalty20-  Sec 25-Q provides punishment of imprisonment to an extent of one month,

or fine up to Rs. 1,000/-, or with both for violation of the requirement of giving notice to

Government and the permission thereafter under Section 25N (1)(c)  or   for
for the violation of 

sub-section
sub-section (4) of Section
Section 25-N of the Act.

19
P.L. Malik- Industrial Law
20
S.M. Chaturvedi- Labour and Industrial laws 13 th Edition

11
 

RETRENCHMENT PROCEDURE -

Section
Section 25-G incorporates
incorporates the well recognised
recognised principle of retrenchment
retrenchment in indust
industrial
rial law,

namely, the “last come first go” or “first come last go.” The Section becomes applicable

only if all the conditio

conditions
ns laid down herein are fully and cumul
cumulatively
atively satisfie
satisfied
d they are:-

(i) The pers

person
on claiming
claiming prot
protection
ection sh
should
ould be a wor
workman
kman as def
defined
ined in secti
section
on 2(s);

(ii) He shou
should
ld be a citizen
citizen of IIndia;
ndia;

(iii) The “industrial establishment” employing such workman must be an “industy”

underr sec 2(j)

unde

(iv) He should belong to a partic

particular
ular category of workmen in that establis
establishment;
hment; and

(v) There should

should not be an agreement between
between the employer and the workman
workman contrary

to the procedure of “last come first go.”

Given all the above conditions, the employer shall “ordinarily” retrench the workman

who was the last person in that category. However, the employer can deviate from this

 procedure on justifiable reasons which should be recorded.

Last come first go- The principle of “last come first go” is statutorily incorporated

in Section 25-G. If a case for retrenchment is made out, it would normally be for the

employer to decide which of the employees should be retrenched. However, this rule is

not intended to deny the freedom of the employer to depart from it for sufficient and valid

reaso
reasons
ns.. The
The rule
rule “last
“last co
come
me fir
first
st go
go”” is in
inten
tende
ded
d to af
affo
ford
rd a ve
very
ry he
heal
alth
thy
y safe
safegu
guard
ard

discrimination of workmen in regard to retrenchment. The departure from the ordinary

industrial rule of retrenchment without any justification, may itself, in a proper case, lead

to the inference that the impugned retrenchment is the result of ulterior consideration and

hence it is mala fide and may amount to unfair labour practice and victimization. The rule
of ‘last come first go’ has to be complied with for the validity of the retrenchment.

12
 

Departure from the rule “last come first go” .-The rule is that the employers

shall retrench the workman who came last, first, popularly as ‘last come first go’. It is not

inflexible rule and extraordinary situations may justify variations. For instance, a junior 

recruit who has a special qualification needed by the employer may be retained even

thou
though
gh an
anot
othe
herr who
who is on
onee up is re
retr
trenc
enche
hed.
d. But
But th
ther
eree must
must be va
valid
lid reason
reason for
for th
this
is

devi
deviati
ation
on.. The
The burd
burden
en is on th
thee mana
manage
gemen
mentt to subs
substa
tant
ntiat
iatee th
thee spec
specia
iall grou
ground
nd for 
for 

departure from the rule. Section 25-G insists on the rule “last come first go” being applied

ca
cate
tego
gory
ry wis
ise.
e. This
This is to sa
say
y, th
tho
ose who fa
fall
ll in th
thee sa
same
me cate
categ
gory
ory sh
shal
alll su
suff
ffer 
er 

retrenchment only in accordance with the principle of ‘last come first go’. Where   the

seniority list of particular workmen is the same, there is a telling circumstance to show

that
that they
they fa
fall
ll in the
the same
same ca
cate
tego
gory
ry.. Grad
Gradin
ing
g fo
forr pu
purp
rpos
oses
es of scale
scaless of pa
pay
y an
and
d like
like

considerations will not create new categorisation. If grades for scales of pay, based on

length of service, etc. are evolv

evolved,
ed, that process amounts to creation
creation of separat
separatee categories.
categories.

In the
the 1980
1980 Supr
Suprem
emee Cour
Courtt   Jore
Jorehau casee, out of 23 work
hautt Tea Co. cas workme
men
n 16 were
ere

retr
retren
ench
ched
ed in acco
accord
rdan
ance
ce wi
with
th Sect
Sectio
ion
n 25-G
25-G,, but
but th
thee re
rema
main
inin
ing
g 7 wo
work
rkme
men’
n’ss

retrenchment deviated from Section 25-G. Supreme Court observed that grading for the

 purposes of scales of pay and like considerations will not create new categorisation21.

However, it is incumbent upon the employer to record the relevant circumstances and the

reaso
reasons
ns for
for devi
deviati
ation
on fr
from
om th
thee ru
rule
le like
like th
thee ef
effic
ficie
ienc
ncy,
y, un
unre
relia
liabi
bilit
lity,
y, or ha
habi
bitu
tual
al

irregularity of the workmen who is retrenched, so that the tribunal to which the dispute is

take
taken
n will
will be ab
able
le to ascert
ascertain
ain wheth
whether
er th
thee de
depa
partu
rture
re is ju
justi
stifie
fied
d by soun
sound
d an
and
d va
valid
lid

reasons. Therefore, employer’s order of retrenchment deviating the ‘last come first go’

rule must be a ‘speaking order’ otherwise it will be treated as mala fide or amounting to

unfair labour practice and victimization.

21
Om Oil & Oil Seeds Exchang
Exchange
e Ltd v Workmen
Workmen (1966) I LLJ 324 SC

13
 

Effect of departure from ‘last come first go’ rule22- A retrenchment violating
the ‘last

come first go’ rule will be declare

declared
d invalid unless such deviation is suppo
supported
rted by valid

and justifiable reasons. Normally the workman so improperly and illegally detained is

entitled
entitled to reinsta
reinstatement
tement and also for payment of remun
remuneration
eration for the period durin
during
g

which the workman remained unemployed.

Re-employment of retrenched workman-Section 25-H- The rule under section 25-H

 provides that after effecting retrenchment, if the employer proposes to

t o take into his

employment any person.

i) He sha
shall
ll give an opp
opportun
ortunity
ity to the
the retr
retrenched
enched workmen
workmen who offer th
themselv
emselves
es for 
re-employment; and
ii) These retren
retrenched
ched workmen
workmen have pref
preference
erence over the new applicants
applicants.. Thus, Sectio
Section
n
25-H
25-H impo
impose
sess a statu
statuto
tory
ry ob
oblig
ligat
atio
ion
n on th
thee empl
employ
oyer
er to gi
give
ve pref
prefere
erenc
ncee to
retrenched workmen when he subsequently employs any person.

Conditions to apply Section 25-H - The preferential right of employment secured by

Section 25-H to a retrenched workman will be available only if the following conditions

are satisfied:-

(i) The workman

workman sho
should
uld have been
been ‘retrenched’
‘retrenched’ prior
prior to the re-employ
re-employment
ment in question.
question.
In othe
otherr word
words,
s, if th
that
at work
workma
man’
n’ss term
termin
inat
atio
ion
n of empl
employ
oymen
mentt was
was not
not du
duee to
re
retre
trenc
nchm
hmen
ent,
t, but
but due
due to so
some
me ot
othe
herr ev
even
entu
tuali
alitie
tiess like
like di
dismi
smissa
ssal,
l, di
disch
schar
arge
ge or 
superannuation, etc., he cannot claim the preferential right of re-employment under 
this section.
(ii) He sho
should
uld be
be a ccitizen
itizen o
off India.
India.
(iii) He should offer himself for re-employment failing which he will forfeit the right.
The offer is made in response to the notice given by the employer under Rule 76 of 
the Industrial Disputes (Central) Rules, 1957 or corresponding State Rules.

22
Dr Avtar Singh – Introduction to labour and Industrial laws 2 nd editon

14
 

(iv) The workm

workman
an should hav
havee been retrenched from the same category
category of service in the
industrial establishment in which the re-employment is proposed.
It is not the designation, but the nature of the work that will decide the category of the

 post. Thus, a workman who was designated as assistant storekeeper, but who was

su
subs
bsta
tant
ntia
ially
lly do
doin
ing
g cleri
clerical
cal work
work wa
wass re
retre
trenc
nche
hed.
d. Subs
Subseq
eque
uent
ntly
ly,, th
thee mana
manage
geme
ment
nt

employed three persons as clerks in that establishment. It was held that Section 25-H is

violated as the retrenched workman is not given preferential re-employment.

Section 25-H only prospective in effect - not retrospective in application.

Sectio
Section
n 25-H
25-H not applic
applicabl
ablee - if closur
closuree or tr
trans
ansfer
fer of under
undertaking--   Section
taking Section 25-H

when
when it gives
gives prefere
preference
nce to retren
retrenche
ched
d workme
workmen
n indica
indicates
tes that
that the prefere
preference
nce will be

available to those workmen who were retrenched individually. It will not apply to a case

where either because of transfer of business or closure, the services of all workmen are

terminated. This can be only possible view because the definition of retrenchment under 

Se
Sect
ctio
ion
n 2(00
2(00)) of the
the Act
Act do
does
es not
not sp
spec
ecif
ifica
ically
lly in
incl
clud
udee th
thee ca
case
se eit
eithe
herr of trans
transfe
ferr of 

 business or of a closure of an industry.

Terms and conditions of service when re-employed. - There is difference of opinion by

the various courts as to whether re-employment connotes taking back into employment or 

service on the same terms and conditions to which the employee was entitled previously.

The
The Bomb
Bombay
ay High
High Co
Cour
urtt hold
holdin
ing
g th
that
at th
ther
eree is no
noth
thin
ing
g in th
thee secti
section
on or an
any
y ot
othe
her 
r 

 provision in the Act which gives the workman a right to secure re-employment on his

 previous terms and conditions of service.

Back Wages   :  Retrenched employees later reinstated in service pursuant to the orders

of a tribunal or courts are not entitled to back wages as a matter of right for the period

when they were out of employment.

15
 

RETRENCHMENT COMPENSATION ON TRANSFER OF UNDERTAKING

Section
Section 25-F
25-FF-Scope of -   Under Section 25-FF of the Industrial Disputes Act, 1947,
F-Scope

where the ownership or management of an undertaking is transferred by agreement or by

operation of law to a new employer, the workmen are entitled to notice and compensation

as contemplated in Section 25-F, as if they had been retrenched. But this is not applicable

to such transfer if:-

(a) The serv

service
ice of the workmen
workmen has no
nott been inter
interrupte
rupted
d by such transfer;
transfer;

(b) The terms and co

conditio
nditions
ns of services of the wor
workmen
kmen after such tra
transfer
nsfer are not

les
esss favou
favourable
rable than those before
before the transfer;

(c) The new

new emp
employ
loyer
er is legally
legally lia
lia bl
 blee to pay compensation in case of retrenchment

on the basis of continuous service as if there was no break in service by the

transfer.

Legislative background.- Section 25-FF was originally introduced in Chapter VA by

Industrial Dispute (Amendment) Act, 1956. The Supreme Court in  Hari Prasad

Shivashankar Shukla v. A.P. Divelkar 23,  and  Barsi Light Railway Co.Ltd. v. K.N.

Jogalkar24, held that no retrenchment compensation under Section 25-F was payable to

workmen whose services were terminated by the employer on a real and bona fide closure

of business or when termination occurred as a result to transfer of ownership from one

employ
employer
er to anothe
another.
r. The origin
original
al Sectio
Section
n 25-FF
25-FF was negativ
negativee in nature
nature.. The above

decision of the Supreme Court demanded amendment to Section 25-FF hence, Section

25-F
25-FF
F was
was re
recas
castt to its pr
prese
esent
nt fo
form
rm by th
thee In
Indu
dustr
stria
iall Disp
Disput
utes
es (Ame
(Amend
ndme
ment
nt)) Ac
Act,
t,

1957.The amended Section has made it clear that the employer is liable to give notice and

 pay compensation in case of transfer of undertaking to workmen.

23
AIR 1957 SC 121
24
(1957) I LLJ 243 (SC)

16
 

Conditions to be fulfilled to be entitled for compensation-  the notice and compensation

as in retrenchment are available only on satisfaction of the following conditions: -

(i) There should be a transfe

transferr of ownersh
ownership
ip or manag
management
ement of an undertaking
undertaking from

employment to another by agreement or by operation law; and

(ii) Such u
underta
ndertaking
king must
must be an
an ‘industry
‘industry’’ within the me
meaning
aning of Secti
Section
on 2(
2(j);
j); and

(iii) The workm

workmen
en claiming the rights
rights should be one coming within
within the definition
definition of 

‘workmen’ under Section 2(s); and

(iv) Such w
workme
orkmen
n shoul
should
d hav
havee put in a min
minimum
imum o
one
ne year’s
 year’s continuous service

immediately before the transfer of management or 

management  or   ownership.
ownership.

Transfer of Management or ownership -  the primary condition to attract Section 25-FF

is that the ownership or management of an undertaking is transferred from the employer 

in relation to that undertaking to a new employer. If the transfer is fictitious or benami,

the section has no application. The transfer of the ownership or management of the entire

undertaking must take place. Any partial transfer like transferring a branch or department

of an undertaking will not attract Section 25-FF.

In   R.S Madho Ram & Sons Agencies v. Workmen25, a partnership firm dealing in

varied allied lines of business transferred one of its businesses, namely, retail business to

a newly incorporated private company. The Supreme Court held that this transfer was not

covered by Section 25-FF for the following reasons. There was a common muster roll for 

all the employees, the same set of conditions governed them, they were subject to inter-

department transfers, they were treated as one unit for the purpose of bonus and they were

not employed for any particular branch or line of business. Further, it was manifest that

the retail business department

department could not be consider
considered
ed to be a separat
separatee undertaking
undertaking or 

25
(1964) I LLJ 366 (SC)

17
 

establishment for the purpose of Section 25-FF of the Act. The transfer of the undertaking

underr Section
unde Section 25-F
25-FF
F does not necessarily include the transf
transfer
er of employees as well.

In   Ambal
Ambala
a Ca
Cant
nton
onme
ment
nt Ele
Elect
ctri
rica
call Supp
Supply
ly   Corp
Corpor
orat
atio
ion
n v. Wo
Work
rkmen26, the
men

Corporation was taken over by the Punjab State Electricity Board as per the provisions of 

the Indian Electricity Act, 1910. Some of the old corporation workers were recruited to

the
the new
new Bo
Board
ard as fresh
fresh en
entra
trant
nts.
s. Cons
Conseq
eque
uent
ntly
ly,, th
thee work
worker
erss claim
claimed
ed retre
retrenc
nchm
hmen
entt

compensation under Section 25-FF from the company. It was held that the compulsory

 purchase of the Corporation by the Board amounted to a transfer of the management of 

the undertaking from one employer to another employer even though it did not involve

the transfer of the employees. Hence, the workmen were entitled to compensation under 

Section 25-FF in such transfer, court can review and issue appropriate directions as to

serv
servic
ice,
e, be
bene
nefi
fits,
ts, re
re-em
-empl
ploy
oymen
mentt of empl
employ
oyee,
ee, et
etc.
c. Simi
Simila
larly
rly,, wh
when
en a go
gove
vern
rnme
ment
nt

undertaking is taken over by the Company along with the employees for the continued

working of the undertaking, it was held that the employees ceased to be employees of the

government but became employees of the Company.

The Obl
Obliga
igatio
tion
n to pay Com
Compen
pensa
sation:   bec
tion: becom
omes
es de
defin
finite
ite on
only
ly when
when : (a)
(a) th
ther
eree is

retrenchment to the employee, or (b) the ownership or management of the undertaking is

except in cases mentioned in the proviso to Section 25-FF, transferring to a new employer.

Hence, the right under Section 25-FF does not arise either before the determination of 

employment or before the transfer of the undertaking 27.

26
AIR 1971 Punj & Har 274
27
Comm of Income Tax, Kerala v Gemini Cashew Sales Corporation , Quilon AIR 1967 SC 1559

18
 

When Section 25-FF rights are not available.-

(i) The ser

service
vice of the wo
workmen
rkmen has
has not b
been
een interrupt
interrupted
ed by ssuch
uch tra
transfer;
nsfer;

(ii) The terms and con

condition
ditionss of service appli
applicable
cable to the workmen
workmen after such tran
transfer
sfer are

no
nott in any
any way
way le
less
ss fa
favo
vour
urab
able
le to th
thee work
workme
men
n th
than
an th
thos
osee appl
applic
icab
able
le to hi
him
m

immediately before the transfer; and

(iii) The new employer is, under the term of such transfer or otherwise, legally liable to

 pay to the workman, in the event of his retrenchment, compensation on the basis that

his service has been continuous

continuous de has not been interrupted
interrupted by the transfer.

Retre
Retrench
nchmen
mentt by trans
transfer
feree
ee attra
attracts
cts Se
Sect
ction
ion 25-F
25-F and not Sectio
Section
n 25-FF ----   In
25-FF --

Workmen of Subong Tea Estate v. Subong Tea Estate 28, the estate was transferred to

Hi
Hind
ndus
usta
tan
n Tea
Tea Comp
Compan
any
y an
and
d po
posse
ssessi
ssion
on wa
wass ha
hand
nded
ed ov
over
er.. All
All its em
empl
ploy
oyees
ees got
got

instructions
instructions about their work and received their salaries from the Hindustan
Hindustan Tea Compa
Company
ny

on 17-2-1959. The manager of the vendor with permission of the vendee retrenched 8

work
workers
ers af
afte
terr pa
paym
ymen
entt of re
retr
trenc
enchm
hmen
entt co
comp
mpen
ensat
satio
ion
n on 31
31-8
-8-1
-195
959.
9. The
The wo
work
rkers
ers

challenged
challenged the validity
validity of the retrenchme
retrenchment
nt on the ground that it contr
contravened
avened Section 25-F

and 25-G. the Supreme Court found that the facts in this case proved that the vendee took 

charge of the estate on 17-2-1959 and so became the employer of the employees who
were working in the estate. Therefore, Section 25-FF is not applicable to the impugned

retrenchment. It is retrenchment effected by the transferee and who in the meanwhile had

 become the employer of the retrenched workmen. In that case Section 25-F and 25-G will

 be applicable. Since Section 25-F and 25-G are not complied with, the retrenched so

declared
declared is inval
invalid
id and the workmen are entitled to reinsta
reinstatement
tement with full back wages
wages..

28
SC (1964) I LLJ 33

19
 

Closure Notice- Section 25-FFA inserted by the 1972 amendment requires an employer who intends

to close down an undertaking to give at least sixty days advance notice in the prescribe manner to the

appr
approp
opri
riate
ate Gove
Govern
rnme
ment
nt.. Th
Thee no
notic
ticee sh
shal
alll clearl
clearly
y state
state th
thee re
reaso
ason
n fo
forr th
thee in
inten
tends
ds clo
closu
sure
re of th
thee

undertaking. The following establishments are exempted from this requirement:

(i)   Undertaking in which less than fifty workmen are employed ;

(ii)   Undertaking in which less than fifty work

workmen
men were employed on an average per working

day in the preceding 12 months ;

(iii)   Und
Undert
ertaki
aking
ng set up for the constru
constructio
ction
n of building
building,, bridg
bridges,
es, roads
roads,, canals,
canals, dams
dams or for 

other
other constru
constructio
ction
n work
work or project
project.. The app
approp
ropriat
riatee Gov
Govern
ernmen
mentt is investe
invested
d with the

 power to give exemption from this provision to any undertaking for such specified period,

if the Government is satisfied that owing to such exceptional circumstances as accident to

the undertaking or death of the employer or the like it is necessary to do so.

Compens
Compensation
ation in case of Closure of undertaking--Section 25-FFF: Scope of the

Section29-Se
-Secti
ction
on 25-
25-FF
FFF
F was substit
substitute
ute in 1957
1957 by the Indust
Industrial
rial Disput
Disputes
es (Amend
(Amendmen
ment)
t) Act,
Act, 195
1957
7 to

override the decision of the Supreme Court. The Section is focused to provide some relief to the workmen

whose
whose servic
services
es stand
stand termin
terminate
ated
d conseq
consequen
uentt to the clo
closin
sing
g dow
down
n of an undert
undertaki
aking
ng exc
except
ept on certain
certain

situations. Under the section, where an undertaking is closed down, every workman, who has not less than

one year’s continuous service in that undertaking before the closure, is entitled to notice and compensation as

 provided in Section 25-F. however, the proviso to Section 25-FFF(i) says that if the closing down of the

undertaking is on account of unavoidable circumstances beyond the

29
S.N. Mishra- Labour and Industrial Laws 24 th Edition Central law Publication

20
 

control of the employer, then the compensation under Section 25-F (2) shall not exceed

the workmen’s
workmen’s averag
averagee pay for three months.

Explanation to the above proviso says that a closure of the undertaking due to any of the

following
following reason
reasonss   sh
shal
alll no
nott be de
deem
emed
ed to be cl
clos
osur
uree on ac
acco
coun
untt of un
unav
avoi
oida
dabl
blee

circumstances
circumstances beyon
beyond
d the contr
control
ol of the employer. The reasons are:

(i) Fin
Financi
ancial
al diffi
difficul
culties
ties or fina
financi
ncial
al lo
losses
sses of the
the eempl
mploy
oyer
er ; or 
or 

(ii) Accumu
Accumulati
lation
on of ind
indisp
ispose
osed
d sstoc
tocks
ks ;or 

(iii)
(iii) Expiry
Expiry o
off the peri
period
od of leas
leasee or lic
licenc
ence.
e.

Sub-section (2) of section 25-FFF exempted the employer from the liability to give notice

and pay compensation on the closing down of an undertaking in the following situation;-

(a)   The undertaking is set up for the construction of bu

buildings,
ildings, bridges, roads,
canals, dams or other construction work, and

(b)   The unde

undertakin
rtaking
g is closed do
down
wn within two year
yearss from the date on which it

was set up ;

(c)   The closu

closure
re is due to the completing
completing of the work.

(i)   To provid
providee relief in the event of any involu
involuntary
ntary unemploy
unemployment
ment in case of 

closure of an undertaking;

(ii)   To infuse a sense of security in the worker in relation to his job from the

absolute
absolute will and pleasur
pleasuree of the emplo
employer
yer ;

(iii) To raise the position and status of labour and to standardizes its rights in relation

to industry.30

30
O.P.Malhotra- Labour and Industrial Law

21
 

Whether Section 25-FFF infringes Articles 14 and 19 (i)(g) of the Constitution .-

The Supreme Court in many cases had held that Section 25-FFF does not violate the

equal protection clause of Article 14 as the impugned Section 25-FFF applied to all the

industr
industrial
ial which
which fall
fall within
within a certain
certain group ad that
that the cla
classif
ssifica
ication
tion made therei
therein
n is

reasonable because it is not arbitrary and that it is related with the object sought to be

achieved by the Act. Similarly, the fundamental right under Article 19(i)(g) to carry on

trade or occupation which included to close down the business is also not violated by

Section
Section 25-FFF in view of the reasonable restrictio
restrictions
ns attached to the right.

Closure differs from Retrenchment-

(i
(i)) In the
the ca
case
se of closu
closure
re th
thee un
unde
dert
rtak
akin
ing
g is clo
closed
sed or pe
perm
rman
anen
ently
tly di
disco
scont
ntin
inue
ued,
d,

whereas
whereas in retrenc
retrenchme
hment
nt the bus
busine
iness
ss continu
continues
es its ope
operati
ration
on eve
even
n thoug
though
h the

services of some of the workers are terminated due to surplusage or due to any

other reason.

(ii) Notice or wage

wagess in lieu of notice and payme
payment
nt of compensation
compensation under section
section 25-F

(a) and (b) are condit

condition
ionss preced
precedent
ent for a valid
valid retrenc
retrenchme
hment.
nt. Retrenchm
Retrenchment
ent is

 prohibited without first satisfying those requirements. Any retrenchment before

complying with those conditions will be invalid and inoperative. But such notice

or wages in lieu of notice and compensation are only the resultant rights of the

wo
work
rkme
men
n wh
whos
osee se
serv
rvic
ices
es ar
aree te
term
rmin
inat
ated
ed cons
conseq
eque
uent
nt to th
thee cl
clos
osur
uree of th
thee

undertaking.

(iii) The ‘last come first go’ rule under section 25-G and the duty to give preference to

the retrenched workman in case of re-employment under section 25-H which are

strictly applicable in case of closure. Section 25-H is never attracted to cases of 

transferr of busin
transfe business
ess or of closure of an industry.
industry.

22
 

Distinction between lay-off and Retrenchment

a) Term
Term lay off
off ha
hass been
been define
defined
d in Sec
Sec 2(k
2(kkk)
kk) and
and the
the ter
term
m retrenc
retrenchme
hment
nt in Se
Secc 2 (o
(oo)
o)

 b) In case of lay-off there is failure, refusal or inability of the employer to give

em
empl
ploy
oymen
mentt to a work
workme
men
n fo
forr a tempo
tempora
rary
ry perio
period
d wh
while
ile in retre
retrenc
nchm
hmen
entt th
thee

workman is deprived of his employment permanently.

c) Lay-off
Lay-off iiss on accou
account
nt of o
one
ne or more
more rreaso
easons
ns mentio
mentioned
ned in
in Sec 2
2(kk
(kkk)
k) while
while in

retrenchment
retrenchment the termination is on the ground of service of labou
labour.
r.

d) The reason
reasonss of lay-o
lay-off
ff are entirely
entirely dif
different
ferent as co
compared
mpared to reasons
reasons of retrenchm
retrenchment.
ent.

e) In lay-off
lay-off the labour
labour forc
forcee is not surplu
surpluss but in re
retrench
trenchment
ment it
it is surplu
surpluss which
which h
has
as

to be retrenched.

f) In llay-of
ay-offf the relatio
relationship
nship of eemploy
mployment
ment is n
not
ot termina
terminated
ted w
while
hile in retrenchment
retrenchment it

is terminated.

g) In lay-off
lay-off the relationship
relationship of em
employ
ployment
ment is only
only su
suspend
spended
ed while
while in retren
retrenchment
chment it

is terminated.

h) Consequences
Consequences of both
both are d
differen
ifferentt to each other and are g
govern
overned
ed by differe
different
nt

norms.

23
 

Conclusion
Industry must be given due emphasis, it is a fact that the development of industry is

correlated to labour contentment. Therefore to achieve this, our country aims to create

a welf
welfare
are State
State on a so
socia
cialis
listic
tic pa
patte
ttern
rn of soci
society
ety as ex
expr
pres
essly
sly embo
embodi
died
ed in ou
our 
r 

Constitution of India. Employers often use the weapon of retrenchment in Downsizing

Policy to lessen their workforce due to heavy expenses. Downsizing literally means to

reduce the size of the organization by cutting down the number of employees presently

working in the company. The major techniques of adopting downsizing strategy are

retrenchment, lay-off, closure and voluntary retirement.

Suggestions

1. Bring
Bringing
ing awareness
awareness amongst
amongst the workers regarding
regarding th
thee various ben
benefits
efits available
available to

them with regard to retrenchment compensation

2. Workm
Workmen
en must be encouraged
encouraged to approach
approach competitive
competitive aut
authority
hority to bri
bring
ng abou
aboutt

amicable solution between the management and the workmen.

3. The Cha
Charter
rter of Demands
Demands system,
system, which is more prevalent
prevalent in recent times,
times, must be

 beneficial to both workmen and management, it shall mention the terms of 

retrenchment compensation.

4. Dow
Downsi
nsizing
zing is also aimed at increas
increasing
ing profitab
profitabilit
ility
y by red
reducin
ucing
g the costs
costs as well
well as
enhanci
enhancing
ng and improv
improving
ing the produc
productiv
tivity
ity of the ret
retain
ained
ed employ
employees,
ees, but the fear 
fear 

arises that the performance of the retained employees might be reduced because of 

 job stress they experience due to additional workload on them. In order to ensure

 performance the retained workers sshould

hould be motivated.

5. Whi
While
le follow
following
ing the proces
processs of retren
retrenchm
chment
ent the workme
workmen
n mus
mustt be pro
provid
vided
ed with
with

other employment opportunities in other industries and compensated for the period of 

unemployment.

24
 

Bibliography

Books Referred: -

1. P. L. Ma
Malik
lik – IInd
ndus
ustr
tria
iall Law
Law – 22nd Edition
22

2. Pro
Proff K.M
K.M.. P
Pilla
illaii – Lab
Labou
ourr a
and
nd Ind
Indust
ustria Laws 11th Edition 2007
riall Laws

3. S. M C
Chat
haturv
urvedi
edi – Labo
Labour
ur and Ind
Indus
ustr
trial
ial laws- 13th Edition Central
laws-

Law Agency

4. Dr Avta
Avtarr Singh
Singh – Int
Introd
roduct
uction
ion to La
Labo
bour
ur and
and IIndu
ndustr
strial laws 2nd Edition 2008
ial laws

5. S.N
S.N.. Mis
Mishr
hra-
a- Labou
Labourr and Ind
Indus
ustr
trial
ial Law 24th Edition Central
Lawss 24

Law Publication

6. O.P
O.P.Ma
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lhotr
tra-
a- Labou
Labourr a
and
nd Ind
Indust
ustria
riall La
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w – vol 2

25