THE PUNJAB NATIONAL BANK, LTD. vs ITS WORKMEN

The Supreme Court held that the dismissal of employees by the Bank during a pen-down strike was invalid under Section 33 of the Industrial Disputes Act, 1947, as the Bank failed to conduct a proper inquiry or obtain permission from the Tribunal. The Court affirmed the Labour Appellate Tribunal's decision that, despite the strikes being illegal under Section 23(b), the Bank had waived its right to penal action by entering into an agreement with the Government. Consequently, the Court upheld the reinstatement of 136 employees while denying it to others found guilty of subversive activities.