FEROZ DIN AND OTHERS vs THE STATE OF WEST BENGAL

The Supreme Court held that the notices issued by the company effectively discharged the workers and did not constitute a lock-out under Section 2(1) of the Industrial Disputes Act, 1947. The Court clarified that the removal of workers' names from the rolls was a mere formality and did not negate the discharge. Furthermore, it ruled that the sanction under Section 34(1) of the Act was valid if evidence showed that all necessary facts were presented to the sanctioning authority, even if not explicitly stated in the sanction itself.