RESERVE BANK OF INDIA, BOMBAY vs C.T. DIGHE AND OTHERS

The Supreme Court held that changes made by an employer in the promotion scheme during the pendency of a reference before a Tribunal do not automatically contravene Section 33(1)(a) of the Industrial Disputes Act, 1947. The Court emphasized that the legality of such changes depends on the nexus between the changes and the nature of the pending reference. The National Tribunal's award was set aside, and the complaints were dismissed, affirming the employer's right to modify promotion criteria under certain conditions.