SHRI AMBALAL M. SHAH AND ANOTHER vs HATHISINGH MANUFACTURING CO., LTD.

The Supreme Court upheld the validity of the Central Government's order under Section 18A of the Industries (Development and Regulation) Act, 1951, allowing the takeover of management of an industrial undertaking. The Court clarified that the initiation of an investigation under Section 15 does not need to be based solely on the opinion mentioned in Section 15(b), but can also be based on Section 15(a)(1). The ruling emphasized that as long as an investigation under Section 15 has been conducted, the Central Government can act if it believes the undertaking is being managed detrimentally to public interest.