GYANENDRA SAHAY vs M/S. TATA IRON & STEEL CO. LTD.

The Supreme Court held that the acceptance of the appellant's resignation on the same day it was submitted raised doubts about its voluntariness, indicating coercion. The Court emphasized that under the Bihar Shops & Establishments Act, a resignation obtained under duress is tantamount to illegal termination. The Court reversed the High Court's decision, reinstating the appellant with full back wages and benefits, thereby upholding the Labour Court's award.