H.R. ADYANTHAN vs SANDOZ (INDIA) LTD.

The Supreme Court identified a conflict between multiple three-Judge Bench decisions regarding the interpretation of Section 2(s) of the Industrial Disputes Act, 1947, particularly concerning the status of medical and sales representatives before the enactment of the Sales Promotion Employees (Conditions of Service) Act, 1976, and the subsequent amendment in 1984. The Court determined that the matter requires clarification and thus referred it to a larger five-Judge Bench for resolution. This referral underscores the importance of consistent interpretation of statutory definitions in labor law.