AUTOMOBILE PRODUCTS OF INDIA EMPLOYEES UNION vs ASSOCIATION OF ENGINEERING WORKERS, BOMBAYAND ORS.

The Supreme Court held that under Sections 10-15 and 19 of the Maharashtra Recognition of Trade Unions & Prevention of Unfair Labour Practices Act, 1971, the recognition of a trade union cannot be granted based solely on a secret ballot, as it undermines the statutory provisions. The Court emphasized that the recognition process must consider the interests of all workers and cannot be based on mere membership qualifications. The Court upheld the Industrial Court's decision to investigate union membership but clarified that consent to an illegal procedure does not validate the outcome.