STRAWBOARD MANUFACTURING CO. vs GOBIND

The Supreme Court held that under Section 33(2)(b) of the Industrial Disputes Act, 1947, an employer can dismiss an employee before obtaining approval from the Tribunal or Labour Court, provided that the employer simultaneously pays wages for one month and applies for approval. The Court clarified that the dismissal and the application for approval should be part of the same transaction, emphasizing that the legislature intended for employers to have the right to dismiss employees subject to these conditions. The Court approved the decision in Metal Press Works Ltd. v. Deb (H. R.) and disapproved of the rulings in Premier Automobiles Ltd. v. Ramchandra Bhimayya and Indian Extractions Private Ltd. v. A. V. Vyas.