MAHABIR JUTE MILLS LTD. GORAKHPUR A vs SHIBBAN LAL SAXENA AND ORS.

The Supreme Court held that under Section 3 of the U.P. Industrial Disputes Act, 1947, the Government is not entitled to rely solely on a secret report from the conciliation officer when deciding whether to refer a dispute for adjudication. The Court emphasized that administrative orders should ideally be speaking orders, especially when they affect the rights of parties, and that principles of natural justice must be adhered to. The Court upheld the High Court's decision to quash the Government's order refusing to make a reference, as it was based on prejudicial secret information without proper disclosure to the parties involved.