GRINDLAYS BANK LTD. vs CENTRAL GOVERNMENT INDUSTRIAL TRIBUNAL AND ORS.

The Supreme Court held that under the Industrial Disputes Act, 1957, particularly sections 11, 17, and 17-A, a Tribunal has the ancillary power to set aside an ex parte award if a party is prevented from appearing due to sufficient cause. The Court clarified that such an award, made without notice, is a nullity, and the Tribunal must hear the matter afresh. The ruling distinguished between procedural review and review on merits, affirming that the Tribunal retains jurisdiction to set aside the ex parte award and is not functus officio.