WORKERS OF THE INDUSTRY COLLIERY,DHANBAD vs MANAGEMENT OF THE INDUSTRYCOLLIERY.

The Supreme Court ruled that under Section 20(2)(b) of the Industrial Disputes Act, 1947, conciliation proceedings are not concluded until the report is received by the appropriate Government, not merely sent. The Chief Labour Commissioner is not an agent of the Government for receiving such reports unless expressly delegated. The Court held that the appellants' strike on November 7, 1949, was illegal as it occurred before the report was received by the Government on November 17, thus violating Section 22(1)(d) of the Act.