Hindalco Industries Ltd vs Union Of India & Ors

The Supreme Court held that Section 25-O of the Industrial Disputes Act, 1947 applies only to voluntary closures and not to closures mandated by external authorities, such as the Divisional Forest Officer. The Court clarified that the appellant's closure due to a directive was not an intended closure under the Act, thus the requirement for prior permission was not applicable. The Court upheld the High Court's decision, affirming that the conditions imposed for closure were valid under the circumstances.