WESTERN INDIA MATCH CO. LTD. vs WESTERN INDIA MATCH CO. WORKERS UNION & ORS.

The Supreme Court held that under Section 4(k) of the U.P. Industrial Disputes Act, 1947, the State Government may refer an industrial dispute for adjudication at any time, provided that an industrial dispute exists or is apprehended at that time. The Court clarified that the espousal of an individual dispute by other workmen can convert it into an industrial dispute, and this community of interest must exist at the time of reference, not when the cause arose. The Court upheld the validity of the reference made by the State Government in 1963, despite the workman's initial non-membership in the union at the time of termination.