POWERS AND DUTIES OF REGISTRAR AND COLLECTIVE BARGAINING

This article is written by R Tushar Beeshm of 3^rd Year of REVA University, an intern under Legal Vidhiya

ABSTRACT

The concept of collective bargaining is pivotal to maintaining harmonious industrial relations and resolving disputes between employers and workers. In India, the process of collective bargaining is governed by legal frameworks like the Trade Unions Act of 1926 and the Industrial Disputes Act of 1947. The Registrar of Trade Unions, a key authority appointed by the government, holds significant powers and responsibilities in overseeing trade unions and the collective bargaining process.

This article delves into the role of the Registrar, including powers such as registering and deregistering trade unions, facilitating name changes and amalgamations, examining financial statements, and conducting limited inquiries. It also discusses the collective bargaining process in India, covering stages like charter of demands, negotiations, agreements, strikes/lockouts, and conciliation/adjudication. Different levels of collective bargaining, including national, industry, and enterprise/plant levels, are explored.

The article examines collective bargaining agreements, their types (bipartite, settlements, consent awards), and typical contents like wages, benefits, and dispute resolution mechanisms. Limitations on the Registrar’s powers, such as lack of quasi-judicial authority, restricted inquiry scope, and inability to verify membership or decide rival claims, are highlighted. Challenges like resource constraints, conflicts of interest, and practical difficulties are also discussed.

Overall, the article underscores the Registrar’s crucial role in ensuring compliance with legal provisions and fostering a positive labor relations environment through the collective bargaining process.

KEYWORDS

Collective Bargaining, Registrar of Trade Unions, Trade Unions Act, Industrial Disputes Act, Labor Relations, Collective Bargaining Agreements, Labor Laws, Industrial Disputes, Powers, Duties, Limitations.

INTRODUCTION

Collective bargaining is a fundamental aspect of industrial relations, serving as a mechanism for negotiating terms and conditions of employment between employers and workers represented by trade unions. In India, the Trade Unions Act, 1926, governs the registration, functioning, and regulation of trade unions, ensuring a balanced and effective collective bargaining system.

At the heart of this legal framework lies the Registrar of Trade Unions, an authority vested with specific powers and duties. The Registrar plays a crucial role in overseeing and facilitating the collective bargaining process, acting as a guardian of the rights and responsibilities of both employers and workers.

The Trade Unions Act, 1926, confers upon the Registrar the power to decline trade union registration under certain circumstances, such as if the proposed name is identical or closely resembles that of an existing trade union, or if it may cause confusion or deceive the public or the trade unions involved. Additionally, the Registrar has the authority to revoke or withdraw the registration of trade unions in cases of non-compliance with the Act’s provisions.

Conversely, the Registrar is obligated to register trade unions that comply with the requirements of the Act and issue certificates of registration, which serve as conclusive proof of their formal registration. The Registrar also plays a vital role in facilitating changes in trade union names, amalgamations, and registering dissolutions, ensuring transparency and accountability in the operations of trade unions.

While the Registrar’s powers are broad, they are subject to certain limitations, including the inability to verify membership, conduct elections, hold judicial inquiries, decide rival claims, or determine admission of members. These limitations are in place to maintain the impartiality and integrity of the Registrar’s office and to ensure that internal disputes within trade unions are resolved through appropriate legal channels.

This article delves into the intricacies of the Registrar’s powers and duties, as well as the collective bargaining process in India. It explores the definition, importance, and legal framework of collective bargaining, as well as the stages involved, from the charter of demands to negotiations, collective bargaining agreements, strikes and lockouts, conciliation, and adjudication. By examining the roles, responsibilities, and limitations of the Registrar, this article aims to provide a comprehensive understanding of the mechanisms that govern industrial relations and collective bargaining in India.

WHAT IS A TRADE UNION?[1]

Before exploring the powers and duties of the Registrar, it is essential to understand the concept of a trade union. Under section 2(h) of the Trade Unions Act of 1926, a trade union is defined as “any combination or association of individuals founded upon mutual trust, understanding, and cooperation to safeguard common interests.” This definition encompasses organizations representing both workers and employers, formed to regulate relationships among various stakeholders involved in industrial production and processes.

The primary objectives of a trade union are twofold:

1. To regulate relationships among workers and employers, workers and workers, and employers and employers.
2. To place constraints on the functioning of any trade or business, including federations comprising two or more trade unions.

The Trade Unions Act underscores the mission of trade unions to maintain balanced and harmonious relationships among individuals involved in industrial production and processes, achieving necessary adjustments as required.

APPOINTMENT OF THE REGISTRAR

The Registrar of Trade Unions plays a crucial role in the administration and oversight of trade unions in India. Section 2(f)^[2] of the Trade Unions Act, 1926, defines the Registrar as an individual appointed by the Appropriate Government under Section 3 of the Act. The definition also includes any Additional or Deputy Registrar of Trade Unions.

Section 3[3] of the Trade Unions Act grants authority to the Appropriate Government, which refers to both the State and Central Government, to designate an individual as the Registrar. The Appropriate Government also has the prerogative to appoint as many Additional Registrars and Deputy Registrars of Trade Unions as it deems necessary. These appointees function under the supervision of the Registrar within their respective states.

The Appropriate Government outlines the responsibilities and functions of the Additional and Deputy Registrars of Trade Unions through an official order. These appointees are thereby authorized to assume the role of the Registrar and exercise the Registrar’s powers within the geographical jurisdiction where the trade union’s registered office is located.

POWERS AND DUTIES OF THE REGISTRAR OF TRADE UNIONS

The Registrar of Trade Unions, appointed by the appropriate government under the Trade Unions Act of 1926, plays a crucial role in the administration and oversight of trade unions and the collective bargaining process. The Registrar’s powers and duties include:

1. Power to Decline Trade Union Registration (Section 7)[4]: The Registrar has the authority to reject the registration of a trade union if the proposed name is identical or closely resembles an existing trade union or if the Registrar believes that the registration requirements have not been met. In such cases, the Registrar may instruct the applicant to choose a different name before considering the registration. Additionally, the Registrar has the power to request further information and documents if there are concerns that the trade union is not adhering to the provisions of the Act, especially in relation to Sections 5[5] and 6[6] of the Trade Unions Act, 1926.
2. Obligation to Register Trade Unions (Section 8)[7]: If the Registrar is satisfied that the trade union has complied with the provisions of the Act, they are obligated to register the trade union and enter the necessary details in the prescribed register. In the case of A.C.C. Rajanka Lime Stone Quarries’ Mazdoor Union v. Registrar of Trade Unions[8], Govt. of Bihar, the High Court of Bihar ruled that despite the application for registration being submitted on July 31, 1957, no action was taken by the Registrar under Section 7 to request additional documents and information. The Registrar’s failure to fulfill the statutory duty imposed upon him under Section 8 of the Act was noted.
3. Obligation to Provide Certificate of Registration (Section 9)[9]: Upon registration, the Registrar must issue a certificate of registration to the trade union, which serves as conclusive proof of its formal registration.
4. Power to Revoke or Withdraw Registration (Section 10)[10]: Section 10 of the Trade Unions Act, 1926, grants the Registrar the authority to revoke or withdraw the registration of trade unions through various means:
   • When trade unions submit an application for cancellation following the prescribed procedures outlined in the Act.
   • When the Registrar becomes aware and is convinced that the registration was obtained through fraud or error.
   • When the trade union ceases its operations.
   • When, even after receiving notice from the Registrar, trade unions persist in willfully disobeying or violating any provisions of the Act or enforce rules conflicting with the Act’s provisions.
   • When the trade union revokes any rule mandated under Section 6 of the Act.
   • When the Registrar is satisfied that a trade union does not meet the minimum required number of workers, leading to the possibility of registration cancellation. In the case of Tata Electric Companies Officer Guild v. Registrar of Trade Unions[11], 1993 LAB IC 1849, the Trade Union faced issues due to a misunderstanding regarding the accounting year and failed to submit annual returns promptly, rectifying the situation after receiving notice from the Registrar. Consequently, the Registrar ordered the cancellation of the Trade Union’s registration. The Bombay High Court ruled that the Registrar’s order was issued long after the Trade Union had corrected the mistake and thus, the Trade Union’s actions did not constitute willful contravention of the Act’s provisions. Therefore, the court overturned the Registrar’s order for cancellation.
5. Power to Modify Trade Union Name or Facilitate Amalgamation (Section 25)[12]: Section 25 of the Trade Unions Act, 1926, assigns the Registrar the responsibility of facilitating changes in the name or amalgamation of trade unions when formal applications are submitted by said trade unions. These applications must be in the form of a written notice, signed by the Secretary and several members of the trade union desiring to change its name. The notice should also include information about the consent acquired from members for the name change. The notice must satisfy the Registrar and indicate conformity with the Act’s provisions. If the Registrar is content with the submission, they may register the name change in the register, as outlined in Section 8 of the Act, and the change becomes effective from the date of registration. However, if the Registrar is dissatisfied with the notice or finds that the proposed name is identical to that of an existing trade union, they may refuse to approve the name change or amalgamation. For the amalgamation of trade unions, the Registrar of the State where the amalgamated trade union is situated must also be satisfied that the trade union has adhered to the Act’s provisions.
6. Power to Register Trade Union Dissolution (Section 27)[13]: Section 27 of the Trade Unions Act of 1926 requires the Registrar to officially register the dissolution of a trade union upon receipt of formal notice from the trade union itself. This notice must be endorsed by the trade union’s Secretary and seven members and should reach the Registrar within 14 days of the dissolution. If the Registrar determines that the trade union has conducted the dissolution in accordance with the Act’s provisions, they may proceed to register the dissolution, and its effect is recorded from the date of registration. In cases where the trade union’s rules do not provide directives for the distribution of funds upon dissolution, the Registrar assumes the responsibility of distributing these funds among the trade union members in a manner prescribed by law.
7. Power to Examine Audited Statements (Section 28)[14]: Section 28 grants the Registrar the authority to receive annual audited statements that detail all receipts, expenditures, assets, and liabilities of registered trade unions. These statements should cover the year ending on or before December 31 and be submitted in the prescribed manner. Additionally, trade unions are required to send a copy of their rule changes and a statement indicating any alterations made throughout the year to the Registrar. Any changes made by the trade union to its rules must be communicated to the Registrar within fifteen days of their enactment.
8. Limited Inquiry Powers (Section 28): The Registrar has limited powers to conduct summary inquiries to satisfy themselves regarding the election of office-bearers and their compliance with the trade union’s rules. In the case of O.N.G.C. Workmen’s Association v. State Of West Bengal And Ors[15], the Calcutta High Court clarified that while the Registrar possesses quasi-judicial powers concerning the registration and cancellation of trade unions, their responsibilities regarding the alteration of trade union office bearers under Section 8, in conjunction with Section 28 of the Trade Unions Act, 1926, are administrative in nature. In a situation where two competing groups assert their status as office bearers of a union, the Registrar’s inquiry and resulting order are characterized as administrative actions. It is important to note that while the Registrar has the power to make necessary entries in their records regarding the office-bearers of a trade union, they cannot adjudicate or decide disputes between rival claimants or groups within a trade union. Such disputes fall within the jurisdiction of civil courts or other competent authorities.

LIMITATIONS ON REGISTRAR’S POWERS

Despite the Registrar’s crucial role, there are certain limitations on their powers:

• Lack of Quasi-Judicial Powers: The Registrar does not possess quasi-judicial powers to adjudicate disputes between rival groups or office-bearers within a trade union. Any disputes of this nature must be resolved through civil courts or other competent authorities. In Kovai Periyar Maavatta Dravida Panchalai Thozhilalar Munnetra Sangam, Coimbatore v. Commissioner of Labour (Registrar of Trade Unions)[16], Chennai, the Madras High Court held that Section 28 of the Trade Unions Act does not confer any quasi-judicial power to decide the dispute between the rival claimants, and even if any decision is taken, such a decision does not have any binding force. The dispute between the rival claimants in a union can only be decided by a civil court.
• Limited Inquiry Scope: The Registrar’s inquiry powers are limited in scope, and they cannot conduct elaborate inquiries or adjudicate disputes regarding the admission of members or other internal matters of trade unions. In IFFCO Phulpur Karmchari Sangh v. Registrar, Trade Union Kanpur[17], the Allahabad High Court held that Section 28(3) of the Trade Unions Act, 1926, read with Regulation 17A, does not contemplate holding any elaborate inquiry, such as one required in judicial or quasi-judicial proceedings. The Registrar is only required to hold a summary inquiry to satisfy themselves before making any change in the register regarding office bearers, whether the elections have been held in accordance with the rules of the trade union.
• No Power to Verify Membership: Under the Trade Unions Act, 1926, the Registrar has no power to verify the membership of registered trade unions. However, Section 28A of the Trade Unions (Amendment) Bill, 1982, seeks to empower the Registrar to verify membership and related matters.
• No Power to Decide Rival Claims: The Registrar cannot resolve disputes pertaining to the election of rival office-bearers of a union. Such disputes can only be decided by a civil court of competent jurisdiction. In Roadways Mazdoor Sabha, UP v. State of UP[18], the Allahabad High Court held that the Registrar has only limited power to make the necessary entry in their records under Section 28 of the Trade Unions Act. The Registrar does not have the power to adjudicate which of the rival claims is correct.
• No Power to Decide Admission of Membership: The Registrar cannot adjudicate disputes regarding the admission of members to a trade union. Such disputes do not fall under the purview of Section 28(1-A) of the Trade Unions Act and must be resolved through civil courts or industrial tribunals. In Borosil Glass Works Ltd Employees Union v. D D Bombode[19], the Supreme Court held that the dispute between persons who are not yet members and the union would not be an internal dispute of the union. A dispute regarding whether a person should or should not be admitted is not a dispute falling under Section 28(1-A) and is open to such persons to approach a civil court for resolution.

CAN THE REGISTRAR’S ORDERS BE CHALLENGED?

Section 11[20] of the Trade Unions Act, 1926, establishes the right to appeal against the Registrar’s orders regarding the registration, withdrawal, or cancellation of a trade union’s certification. The concerned party has the option to file an appeal in one of the following venues:

• The High Court located within the jurisdiction where the trade union’s Head Office is situated.
• A Labor Court or Industrial Tribunal within the jurisdiction where the trade union is based.
• Any court that is not inferior to the court of an Additional or Assistant Judge of a principal Civil Court of original jurisdiction.

The Registrar is obliged to adhere to the orders issued by the appellate court. The appellate court holds the authority to accept the appeal, thereby nullifying the Registrar’s order and instructing the Registrar to either register or cancel the registration as deemed appropriate. Conversely, the appellate court can also dismiss the appeal, in which case the Registrar is bound to comply with that decision.

In the case of Bombay Fire Fighters Services Union, Mumbai v. Registrar of Trade Unions[21], dated April 7, 2003, the Union filed an appeal challenging the Registrar’s decision to cancel the Trade Union’s registration, citing continuous violations of section 28 of the Act. The Bombay High Court held that the Registrar’s order failed to meet the requirements of section 10 of the Act because the Registrar did not send the notice to the correct address of the Trade Union. Consequently, the cancellation of the Trade Union’s registration was deemed illegal and improper.

It is important to note that the Trade Unions Act, 1926, does not provide for a second appeal process. Thus, the appellate court’s decision regarding the Registrar’s orders is final and binding.

In the case of Registrar of Trade Unions, West Bengal v. Mihir Kumar Guha[22], an appeal was lodged against a Judge’s order that permitted an appeal under Section 11 of the Trade Unions Act, 1926, challenging the Registrar’s decision to cancel the registration certificate for the Employee’s State Insurance Corporation Employee’s Union. The Calcutta High Court ruled that the Trade Unions Act, 1926, does not provide for a second appeal process.

COLLECTIVE BARGAINING

Definition And Importance

Collective bargaining is a technique through which disputes concerning employment conditions are resolved amicably by agreement rather than coercion. The Supreme Court of India has defined collective bargaining as “the technique by which dispute as to conditions of employment is resolved amicably by agreement rather than coercion.”[23]

The legal framework surrounding collective bargaining aims to foster a positive and productive labor relations environment while balancing the interests of employers and employees. It is generally an effective system, as it usually results in employers undertaking actions to resolve the issues of the workers. However, the legal procedure for pursuing collective bargaining in India is complicated.

Stages Of Collective Bargaining

The collective bargaining process in India typically involves the following stages:

1. Charter of Demands: Trade unions draft a “charter of demands” outlining their grievances and desired changes related to wages, benefits, working hours, and other employment conditions.
2. Negotiation: Representatives of the trade union and the employer engage in negotiations to discuss and debate the demands made by the union.
3. Collective Bargaining Agreement: If an agreement is reached, a collective bargaining agreement is drawn up and entered into between the employer and the trade union(s).
4. Strikes[24] and Lockouts[25]: In the event of a failure to reach an agreement, trade unions may resort to strikes, and employers may initiate lockouts, subject to legal procedures and notice requirements.
5. Conciliation and Adjudication[26]: If negotiations fail, the dispute may proceed to conciliation, mediation, or adjudication by labor courts, industrial tribunals, or national tribunals, as prescribed by law.

Levels Of Collective Bargaining

Collective bargaining in India typically occurs at three levels:

1. National-level Industry Bargaining: Common in core industries such as banks, coal, steel, and oil, where the central government plays a significant role as the employer. In these industries, trade unions do not typically provide guidelines on a charter of demands; instead, both sides – the government and trade unions – set up a “coordination committee” to engage in collective bargaining proceedings. Collective bargaining in the public sector generally suffers if the position of the state government differs from that of the central government. Pay scales for government employees at the national level are revised by Pay Commissions, and wage increases are determined by Wage Boards for several industrial sectors, such as journalists and other newspaper employees. Wage Boards are tripartite organizations established by the government to fix wages and include representatives from workers, employees, and independents.
2. Industry-cum Regional Bargaining: Prevalent in industries where the private sector dominates, such as cotton, jute, textiles, and engineering. Bargaining generally occurs in two stages: company-wide agreements are formed, which are then supplemented with regional (i.e., plant-level) agreements. Basic wage rates and other benefits are usually decided at the company level, while certain allowances, incentives, etc., are decided at the regional or plant level, considering the particular circumstances and needs of the employees. However, such regional agreements are only binding on company management if the employers’ association authorizes it in writing to bargain on its behalf.
3. Enterprise or Plant-level Bargaining: Bargaining at the individual company or plant level, with negotiations occurring between the management and trade unions representing the workers at that specific establishment. The bargaining practices differ from case to case because there is no uniform collective bargaining procedure. Typically, the bargaining council (or negotiating committee) is constituted by proportional representation of multiple unions in an establishment. If multiple unions cannot form a single bargaining entity, the management will then have to negotiate individually with each registered union. In the private sector, employers generally prefer plant-level bargaining because uniformity of wage negotiation can be ignored, and the bargaining power of trade unions can be reduced. Trade unions, on the other hand, insist on plant-level bargaining because the payable capacity of the company is generally higher, and labor issues can be resolved more quickly and easily. However, trade unions can face a dilemma in decentralized plant-level bargaining if the business is experiencing a managerial crisis due to market failures or if the management is reluctant to negotiate with the unions.

COLLECTIVE BARGAINING AGREEMENTS IN INDIA

Types Of Collective Bargaining Agreements

Collective bargaining agreements in India are divided into three classes:

1. Bipartite (or voluntary) Agreements: These agreements are drawn up in voluntary negotiations between the employer and the trade union. As per the Industrial Disputes Act, 1947, such agreements are binding, and their implementation is generally non-problematic because both parties reached the agreement voluntarily.
2. Settlements: These agreements are tripartite, involving the employer, trade union, and a conciliation officer. They arise from a specific dispute referred to an officer for reconciliation. If the officer feels that the parties’ viewpoints have been reconciled and an agreement is possible, they may withdraw themselves. The agreement is then reported back to the officer within a specified time, and the matter is settled.
3. Consent Awards: These are agreements reached while a dispute is pending before a compulsory adjudicatory authority and incorporated into the authority’s award. Even if the agreement is reached willingly, it forms part of the binding award pronounced by the authority established for the purpose.

Contents Of Collective Bargaining Agreements

As part of the collective bargaining mechanism, employers and workmen represented by trade unions enter into collective bargaining agreements, typically structured as memoranda of settlements. These memoranda enumerate various clauses that govern the relationship between the workmen represented by trade unions and employers.

Under Section 18(1)[27] of the Industrial Disputes Act, 1947, such settlements entered into between workmen represented by trade unions and employers are binding upon the parties.

Typically, clauses in the memorandum of settlement pertain to the following:

• Term/Duration of the memorandum of settlement as agreed between the parties
• Settlement terms, typically concerning wages, benefits, allowances, arrears with respect to payment to workers, concessions, work hours, overtime, etc.
• Conditions regarding strikes and lockouts by trade unions and employers, respectively
• Obligations of workmen
• Obligations of the employer
• Penalties with respect to non-compliance with the obligations of workmen and employers
• Dispute resolution mechanisms
• Miscellaneous clauses, including severability, notice provisions, etc.

CONCLUSION

The role of the Registrar of Trade Unions in overseeing and regulating trade unions is pivotal to the effective functioning of the collective bargaining system in India. The powers and duties conferred upon the Registrar by the Trade Unions Act, 1926, are designed to maintain a balanced and fair industrial relations landscape, safeguarding the interests of both employers and workers.

While the Registrar’s powers are broad, encompassing the registration, certification, and oversight of trade unions, there are notable limitations and challenges that must be addressed. The inability to verify membership, conduct elections, or hold judicial inquiries can hinder the resolution of internal disputes and undermine the collective bargaining process’s efficiency.

These limitations highlight the need for a well-defined framework for resolving internal trade union disputes, either through amendments to existing legislation or the establishment of specialized bodies or tribunals. Ensuring the swift and fair resolution of such disputes is crucial for maintaining industrial harmony and facilitating effective collective bargaining.

Furthermore, the Registrar’s office must remain vigilant and impartial in exercising its powers and fulfilling its duties. An unbiased and well-functioning Registrar’s office is essential to uphold the integrity of the collective bargaining system and maintain the delicate balance between the interests of employers and workers.

Collective bargaining itself is a vital component of industrial relations, promoting open communication, negotiation, and mutual understanding between employers and workers. It serves as a peaceful mechanism for resolving disputes, preventing disruptions, and fostering a healthy and productive work environment.

As India’s workforce continues to evolve, and new challenges emerge in the realm of industrial relations, the role of the Registrar of Trade Unions and the collective bargaining process will become increasingly critical. By addressing the limitations and challenges faced by the Registrar’s office and continuously improving the legal framework governing collective bargaining, India can strengthen its industrial relations landscape, promote economic growth, and ensure the well-being of both employers and workers.

REFERENCES

1. 6 S C Srivastava, Industrial Relations and Labour Laws 176-187 (Vikas® Publishing House Pvt Ltd 2012)
2. Nishith Desai Associates, India: Trade Unions and Collective Bargaining, 1, 4-8 (2019), https://www.nishithdesai.com/fileadmin/user_upload/pdfs/Research%20Papers/India-Trade-Unions-and-Collective-Bargaining.pdf.
3. Powers and Functions of Registrar Under Trade Union Act, LawBhoomi, (Apr. 19, 2024, 11:26  PM), https://lawbhoomi.com/powers-and-functions-of-registrar-under-trade-union-act/
4. Adhila Muhammed Arif, All about a collective bargaining agreement in India, IPLEADERS, (Apr. 19, 2024, 09:47  PM), https://blog.ipleaders.in/all-about-a-collective-bargaining-agreement-in-india/

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[1] The Trade Unions Act, § 2(h), No.16, Acts of Parliament, 1926 (India).

[2] The Trade Unions Act, § 2(f), No.16, Acts of Parliament, 1926 (India).

[3] The Trade Unions Act, § 3, No.16, Acts of Parliament, 1926 (India).

[4] The Trade Unions Act, § 7, No.16, Acts of Parliament, 1926 (India).

[5] The Trade Unions Act, § 5, No.16, Acts of Parliament, 1926 (India).

[6] The Trade Unions Act, § 6, No.16, Acts of Parliament, 1926 (India).

[7] The Trade Unions Act, § 8, No.16, Acts of Parliament, 1926 (India).

[8] A.C.C. Rajanka Lime Stone Quarries’ Mazdoor Union v. Registrar of Trade Unions., AIR 1958 Pat 470

[9] The Trade Unions Act, § 9, No.16, Acts of Parliament, 1926 (India).

[10] The Trade Unions Act, § 10, No.16, Acts of Parliament, 1926 (India).

[11] Tata Electric Companies Officer Guild v. Registrar of Trade Unions., (1994) ILLJ 125 Bom

[12] The Trade Unions Act, § 25, No.16, Acts of Parliament, 1926 (India).

[13] The Trade Unions Act, § 27, No.16, Acts of Parliament, 1926 (India).

[14] The Trade Unions Act, § 28, No.16, Acts of Parliament, 1926 (India).

[15] O.N.G.C. Workmen’s Association v. State Of West Bengal And Ors., (1988) IILLJ 335 Cal

[16] Kovai Periyar Maavatta Dravida Panchalai Thozhilalar Munnetra Sangam, Coimbatore v. Commissioner of Labour (Registrar of Trade Unions)., (2004) ILLJ 6 Mad

[17] IFFCO Phulpur Karmchari Sangh v. Registrar, Trade Union Kanpur., (1992) IILLJ 239 ALL

[18] Roadways Mazdoor Sabha, UP v. State of UP., 2010 (127) FLR 221

[19] Borosil Glass Works Ltd Employees Union v. D D Bombode., AIR 2001 SC 378

[20] The Trade Unions Act, § 11, No.16, Acts of Parliament, 1926 (India).

[21] Bombay Fire Fighters Services Union, Mumbai v. Registrar of Trade Unions., (2003) IILLJ 1100 Bom

[22] Registrar of Trade Unions, West Bengal v. Mihir Kumar Guha., AIR 1963 Cal 56

[23] Karol Leather Karamchari Sangathan v. Liberty Footwear Company, (1989) 4 SCC 448

[24] The Industrial Disputes Act, § 2(q), No.14, Acts of Parliament, 1947 (India).

[25] The Industrial Disputes Act, § 2(1), No.14, Acts of Parliament, 1947 (India).

[26] The Industrial Disputes Act, § 7, No.14, Acts of Parliament, 1947 (India).

[27] The Industrial Disputes Act, § 18(1), No.14, Acts of Parliament, 1947 (India).