PATNA ELECTRIC SUPPLY CO., LTD., PATNA. vs BALI RAI & ANOTHER.

The Supreme Court held that under Section 33 of the Industrial Disputes Act, 1947, the key consideration for granting permission to discharge employees is whether the employer has engaged in unfair labor practices or victimization. The Court found that the Industrial Tribunal's determination that the application for discharge was made in good faith was sufficient to grant permission, and thus the Labour Appellate Tribunal erred in reversing this decision. The appeal was allowed, affirming the Industrial Tribunal's order.