M/S Sangham Tape Company vs Hans Raj

The Supreme Court held that the Labour Court has jurisdiction to set aside an ex parte award under the provisions of Order IX Rule 13 of the Code of Civil Procedure, provided sufficient cause is shown. However, the Court clarified that once an award becomes enforceable under Section 17A of the Industrial Disputes Act, 1947, the Labour Court becomes functus officio after 30 days from the date of publication of the award. The Court upheld the High Court's decision to set aside the Labour Court's order, emphasizing the limited jurisdiction of industrial tribunals.