In Brief
A daily-wage helper in an Irrigation Department was terminated twice. Labour and High Courts ordered reinstatement, holding that Chapter VB of the Industrial Disputes Act applied and Section 25N compliance was mandatory. The Supreme Court allowed the State's appeal, holding that an Irrigation Department—despite having over 100 workers—does not qualify as an 'Industrial Establishment' under the Act. While the department may incidentally operate pumps, its predominant functions (water resource management, disaster relief, flood control) are not manufacturing activities. Therefore, Chapter VB protections did not apply, and the termination was lawful.
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