Ashok K Jha & Ors vs Garden Silk Mills & Anr

The Supreme Court addressed the legality of the transfer of employees under Section 42 of the Bombay Industrial Relations Act, 1946, holding that a transfer from one department to another constitutes a change in service conditions if it alters the nature of work. The Court emphasized that the employer must provide notice of change as per Section 42(1) when such a transfer occurs. The Court upheld the Labour Court's decision that the transfer was invalid due to the lack of proper procedure, thereby reinforcing the rights of employees against unilateral transfers without due process.