NATIONAL IRON AND STEEL CO. LTD. & ORS. vs THE STATE OF WEST BENGAL & ANR.

The Supreme Court held that under Section 25F of the Industrial Disputes Act, a single order of reference for multiple concerns is permissible if there is sufficient functional integrality among them. The Court found that the appellants shared a community of interest, justifying the Tribunal's comprehensive award on gratuity and retrenchment. The Court upheld the Tribunal's decision to abolish contract labor, emphasizing that separate references would have unnecessarily increased costs without benefit, thus affirming the Tribunal's award.