PRIYA LAXMI MILLS LTD. vs MAZDOOR MAHAJAN MANDAL, BARODA

The Supreme Court held that under Section 98(1)(a) of the Bombay Industrial Relations Act, 1946, a lock-out is illegal if it relates to matters specified in Schedule III, Item 6(ii), which includes the unemployment of previously employed persons. The Court found that the management's declaration of a lock-out following a lay-off was unjustified, as the Labour Court determined there was no evidence of violence or unruly behavior warranting such action. Consequently, the lock-out was deemed illegal, and the appeal was dismissed.