PUNJAB NATIONAL BANK LTD. vs EMPLOYEES OF THE BANK.

The Supreme Court held that under Section 33 of the Industrial Disputes Act, 1947, the Punjab National Bank could not dismiss its workmen during the pendency of proceedings before an Industrial Tribunal without prior written permission from that Tribunal. The Court found that even if the strike was illegal, the dismissal was unlawful as the requisite permission was not obtained. The Labour Appellate Tribunal's order for reinstatement was upheld, establishing that the protections under Section 33 apply to strikes as well, despite its placement in a different chapter of the Act.