Indian Refrigeration Industries vs Ram Rattan Sharma

The Supreme Court upheld the Industrial Tribunal's award reinstating the respondent-workman, finding the domestic enquiry vitiated due to bias, as the enquiry officer was also the management's standing counsel. The Court emphasized that the management failed to argue for an opportunity to lead evidence to justify the termination at any stage of the proceedings. The Court distinguished this case from Divyash Pandit vs. Management, NCCBM, where the management had actively sought to lead evidence, thus affirming the Tribunal's decision as valid and justifiable under the Industrial Disputes Act.