Karnataka State Road Transport Corpn vs Lakshmidevamma & Another

The Supreme Court referred the matter to a larger bench due to conflicting decisions in Shambhu Nath Goyal vs. Bank of Baroda and Rajendra Jha vs. Labour Court. The Court clarified that there is no actual conflict between the two judgments, as Rajendra Jha's case was decided on its specific facts without contradicting the principles established in Shambhu Nath Goyal's case. The Court emphasized the importance of determining the management's right to adduce additional evidence in proceedings under the Industrial Disputes Act, particularly under Sections 10 and 33.