DHARANGADHARA CHEMICAL WORKS LTD. vs STATE OF SAURASHTRA.

The Supreme Court upheld the Industrial Tribunal's finding that agarias were 'workmen' under Section 2(s) of the Industrial Disputes Act, 1947, establishing that the relationship of employer and employee was determined by the degree of control exercised by the employer over the work. The Court emphasized that the test for this relationship is not merely about directing work but also controlling how it is done. The reference for adjudication under Section 10 was deemed competent, affirming the Tribunal's jurisdiction in such matters.