MANAGEMENT OF HINDUSTAN STEEL LTD. vs THE WORKMEN & ORS.

The Supreme Court held that in cases of closure of an undertaking, Section 25FFF of the Industrial Disputes Act, 1947 applies instead of Section 25F(b). The Court clarified that 'undertaking' refers to a specific project or business activity, and closure of part of a business can constitute closure of an undertaking. The Tribunal's decision to reinstate the employee was upheld, as the notice of retrenchment did not comply with the statutory requirements of immediate compensation under Section 25F(b).