MUMBAI MAZDOOR SABHA vs BENNET COLEMAN & COMPANY LTD. & ORS.

The Supreme Court interpreted Sections 3(ii), 11, and 19 of the Maharashtra Recognition of Trade Unions and Prevention of Unfair Labour Practices Act, 1971, emphasizing that a union must have at least 30% membership for recognition and that estoppel by conduct applies if objections are not raised before the Investigation Officer. The Court held that the Industrial Court must accept the findings of the Investigating Officer and cannot entertain new objections not previously raised, affirming the importance of rational construction of labour legislation.