M/S. BENGAL BHATDEE COAL CO. vs SHRI RAM PRABESH SINGH & ORS.

The Supreme Court addressed the issue of victimization under the Industrial Disputes Act, 1947, specifically Sections 10 and 33(2)(b). The Court held that while a domestic inquiry must be properly conducted, the Industrial Tribunal cannot overturn the findings unless there is a lack of good faith, a basic error, or a violation of natural justice. The Court found that the dismissal of the respondents did not amount to victimization, as the punishment was not grossly disproportionate to the misconduct established.