Madan Mohan Ghosh vs Infar (India) Ltd. And Anr.

The Supreme Court held that the representation of an employer by a legal practitioner before the Industrial Tribunal is governed by Section 36(2), (3), and (4) of the Industrial Disputes Act, 1947. The Court found that the Tribunal's order allowing representation by Amar Roy was made without proper inquiry and lacked supporting evidence regarding his eligibility as an 'officer' of the association. Consequently, the Court set aside the Division Bench's confirmation of the Tribunal's order and remitted the matter for fresh consideration, emphasizing the need for a thorough examination of the relevant documents.