In Brief
This case involved Harinagar Sugar Mills (Biscuit Division), a company that manufactured exclusively for Britannia Industries under job work agreements for 32 years. When Britannia terminated the agreement in 2019, Harinagar applied for business closure under Section 25-O of the Industrial Disputes Act, 1947. The Maharashtra government asked it to resubmit with better reasons. Harinagar argued that failure to grant closure within 60 days meant automatic approval. The Supreme Court held that Article 19(1)(g) protects the right to shut down business subject to reasonable restrictions. The Deputy Secretary lacked authority to demand resubmission—only the Labour Minister could decide. Since no valid order was issued within 60 days, the deeming fiction applied, granting closure. The Court found compelling circumstances: 32 years of exclusive work, loss of sole client, exhausted alternative efforts, and impossibility of continuing. The appeal was allowed and the closure was granted.
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