Secretary, Indian Tea Association vs Ajtt Kumar Barat And Ors

The Supreme Court upheld the Calcutta High Court's order directing the State Government to make a reference under Section 10(1) of the Industrial Disputes Act, 1947 regarding the employment status of the respondent, who was dismissed for disobeying a transfer order. The Court clarified that the Government's decision-making under Section 10(1) is administrative in nature and cannot be closely scrutinized by the courts. The Court affirmed that the existence of an industrial dispute must be determined by the Government, and the High Court's intervention was justified in this case.