VISHWESHWARAIAH IRON & STEEL LTD vs ABDUL GANI

The Supreme Court examined the applicability of the ratio in P.H. Kalyani v. M/s Air France Calcutta concerning termination without a domestic inquiry under the Industrial Disputes Act, 1947. The Court held that the principles established in Kalyani's case, which pertained to Section 33(2) of the Act, do not automatically extend to cases under Section 10 or 10-A where no inquiry was conducted. The Court emphasized the need for a closer scrutiny of the observations made in previous judgments when applied to different sections of the Act, ultimately clarifying the procedural requirements for termination cases without prior inquiry.