CHEMICALS & FIBRES OF INDIA LTD. vs D. G. BHOIR & ORS.

The Supreme Court held that under Section 23(b) of the Industrial Disputes Act, the prohibition on strikes applies even if the dispute involves a single workman, provided the workman's cause is supported by a labour union. The Court clarified that the intention of Section 2A is to allow individual workmen to seek relief without necessitating a general dispute between all employees and the employer. The judgment emphasized that the Act aims to prevent strikes and lock-outs during ongoing proceedings, but recognizes strikes as a legitimate tool in industrial relations, subject to certain limitations.