In Brief
This case settled a conflict in Supreme Court precedent regarding whether Labour Courts/Tribunals can set aside ex parte awards after they become enforceable. The Court held that Tribunals are not functus officio after an award becomes enforceable. If a party demonstrates sufficient cause for its absence before the Tribunal when proceedings were conducted ex parte, the Tribunal may entertain an application to set aside the award within a reasonable time. An award denying a party opportunity of hearing without sufficient cause is a nullity and cannot bind the party. The Industrial Disputes Act, as welfare legislation, grants Tribunals necessary ancillary powers to ensure justice. Mere enforceability does not make an award binding; it must comply with natural justice principles.
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