GENERAL LABOUR UNlON (RED FLAG) BOMBAY vs B. V. CHAVAN AND ORS.

The Supreme Court clarified the definition of 'lock-out' under Section 2(L) of the Industrial Disputes Act, 1947, emphasizing that it involves an employer's refusal to continue employing workmen without an intention to close the business. The Court held that the determination of whether an employer has imposed a lock-out or has genuinely closed an industrial establishment requires an examination of the employer's intention and the circumstances surrounding the closure. The appeals were dismissed, affirming the lower courts' findings that the employers had not engaged in unfair labor practices.