M/S. HARYANA SURAJ MALTING LTD. vs PHOOL CHAND

The Supreme Court addressed whether the Industrial Tribunal/Labour Court is functus officio after an award becomes enforceable, specifically under the Industrial Disputes Act, 1947. The Court noted conflicting decisions in Sangham Tape Co. v. Hans Raj and Radhakrishna Mani Tripathi v. L.H. Patel regarding the timeline for recalling an ex parte award. It held that the issue requires clarification by a larger bench, as the interpretation of Sections 11(1), 17, and 20 of the Act leads to differing conclusions about the Tribunal's powers post-enforcement of an award.