Bangalore Woollen, Cotton and Silk Mills Co. Ltd. v Its Workmen
Rule established
An Industrial Tribunal, in adjudicating a reference, must confine itself to the specific matters within the terms of reference made by the appropriate government under Section 10 of the Industrial Disputes Act; a tribunal that travels beyond the scope of the reference and decides matters not referred to it exceeds its jurisdiction.
Facts
- The appropriate government referred a specific industrial dispute to an Industrial Tribunal for adjudication, framing particular issues within the terms of reference
- The tribunal, in the course of its award, addressed and decided matters that were arguably not encompassed within the specific terms of the reference made by the government
Issue
- Whether an Industrial Tribunal can adjudicate upon matters not falling within the specific terms of reference made by the appropriate government, and what is the consequence of doing so.
Held
- The Supreme Court held that an Industrial Tribunal derives its jurisdiction entirely from the terms of reference; it is a creature of the reference and possesses no inherent jurisdiction beyond what has been specifically referred to it
- Where the tribunal travels beyond the scope of the reference and decides issues not encompassed within it, that part of its award is rendered without jurisdiction and liable to be set aside
- The terms of reference must be construed fairly and reasonably, neither so narrowly as to defeat the object of the reference nor so broadly as to permit the tribunal an unbounded roving inquiry into unrelated matters
- The Court examined the specific award to determine whether the tribunal had, in substance, remained within the fair scope of what had been referred
Ratio Decidendi
An Industrial Tribunal's adjudicatory jurisdiction is coextensive with, and strictly bounded by, the terms of reference made by the appropriate government under Section 10 of the Industrial Disputes Act; any part of an award addressing matters outside those terms is without jurisdiction and can be struck down.
How to use it in an exam
- Central authority for the "creature of reference" principle defining and limiting tribunal jurisdiction, frequently tested alongside questions on the scope and construction of reference orders
- Pair with the general discussion on Section 10 reference procedure and the government's role in framing the terms
- Key line: a tribunal's authority begins and ends with what the government has actually referred to it, no more and no less
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Source
Source: AIR 1962 SC 1363; standard casebook authority on the jurisdictional limits of an industrial tribunal defined by the terms of reference, cross-verify citation before exam use
This is an educational summary, not the judgment itself. Cite the reported version in professional or academic work.