HEAVY ENGINEERING MAZDOOR UNION vs THE STATE OF BIHAR & ORS.

The Supreme Court held that the Heavy Engineering Corporation Limited, being a Government Company under Section 617 of the Companies Act, does not operate 'under the authority of' the Central Government as per Section 2(a) of the Industrial Disputes Act, 1947. The Court clarified that an incorporated company has a separate legal existence and is distinct from its shareholders. Consequently, the reference made by the State Government under Section 10 of the Industrial Disputes Act was valid, as the appropriate government was the State Government, not the Central Government. The appeal was dismissed, affirming the High Court's decision.