THE PATNA ELECTRIC SUPPLY CO., LTD.,PATNA vs THE PATNA ELECTRIC SUPPLY WORKERS'UNION

The Supreme Court held that the Bihar Government's housing scheme for industrial labour was merely recommendatory and lacked statutory force, thus could not impose obligations on employers. The Court found that the Industrial Tribunal and Labour Appellate Tribunal erred in enforcing the scheme as a binding term of employment. The judgment emphasized that while Industrial Tribunals have the power to impose obligations for social justice, the specific award in this case was not justified given the circumstances of industrial evolution in the country.