Recent Labour Laws

• The certified Standing Orders will prevail over Tamil Nadu Electricity Board Employees Conduct Regulations.
S. Alamelu v. The Superintending Engineer, South Areal Electricity System (5) Villupuram, 1990 LLR 457: 1990-1 LLN 489 (Mad HC).

• Certified Standing Orders have the binding force.
Hyderabad Allwyn Ltd. Company (Represented by its Personnel Manager) v. Addl. Industrial Tribunal-cum-wbollr Court, Hyderabad, 1990 LLR 100: 1989-11 LLN 1050 (AP HC).

• Model Standing Orper 24(L), 24(1) - Misconduct - Moses, one of the workmen raised voice against the continuation of strike by the workers union - Was given severe beating by other workers at his residence - Away from the factory ¬Whether assault on him by co-workers at his residence amounts to misconduct within the meaning of S.O. 24(L)? Yes.
Murlidhar Raghoji Savant v. General Manager, Mather & Platt (I) Ltd., 1992 LLR 828: 1992 (64) FLR 78: 1992-J[ LLJ 394 (Born HC).

• Misconduct - Allegations against the petitioner for assault on a co-worker at latter's residence and away from the factory premises - Whether the act of assault away from work place is a misconduct within the meaning of Standing Order 24(1).
C.B. Bidk", v. Mather & Platt IIndia) Ltd., 1992 LLR 113: 1992 (64) FLR 737: 1992-1 LLN 302 (Born He).

• Loss of lien - Petitioner Silk Textile Mills - Respondent No, 1 applied for leave¬Declined due to many other employees already on leave - Despite rejection of leave - Respondent No. 1 remained absent - Whether respondent has lost his lien or has abandoned his service as stipulated by certified Standing Order? No,
Kala Silk Factory v. Phankoo Bakos Yadav, (1993) 66 FLR 481: 1992 LLR 107 (Born HC).

• Uttar Pradesh Industrial Disputes Act - Section 2(s) - Provisions of para 16,7 of the Standing Orders cannot override the statutory provisions contained in the Central Act as also the State Act.
Aftar Mia" v. wbour Court, Bareilly, 1992 LLR 221: 1991(63) FLR 721: 1992-1 LLN 69: (1994) III LLj (Supp) 589 (All HC).

• Terms and condition of contract of employment - Inconsistent with certified standing orders of the company - Which would prevail? - Those contained in the Standing Orders.
Eicher Goodearth Ltd. v. Shri Rnjender Kumar Suni, 1993 LLR 524 (Raj He). 439

• Applicability of - Whether applicable to an employee who is given fresh appointment after superannuation and entitled to the benefits under the standing orders? No.
Edwin A. Daniel v. Labour Court, Coimbatore, 1993 LLR 356 (Mad He).

• Application of Model Standing Orders to an industrial establishment• When permissible?
Chandrakanl Tukaram Nikam v. Municipal Corporation of the City of Ahmedabad, 1993 LLR 617: 1991(63) FLR 31 (Guj HC).

• Clarification of Standing Orders - Appeal against - Within 30 days from the date on which copies are sent - Method of calculation time to the computed for period of limitation - The first day in a series of days shall be excluded.
Badarpur Power Engineers Association v. Deputy Chief Labour Commissioner & Appellate Authority, 1993 LLR 289: 1993-1 CLR 673: 1993 LIC 636: 1993(82) FjR 149 (Del HC).

• Application troder - For modification of Standing Orders - In relation to age of retirement/superannuation of Clerk and Operators - Amendment of Schedule ¬Addition of item lOA - During the pendency of application - Provided framing of Standing Orders regarding age of retirement - Whether certifying officer had jurisdiction to deal with application for amendment.
Gokak Mills (Division of Gokak Patel Volkari Ltd.) v. Workmen of Gokak Mills, 1993 LLR 591: 1993 LIC 1850: 1993(82) FIR 628 (Kar HC).

• Standing Order providing for automatic loss of lien - If a workman remains absent without leave for 8 days - Termination of service of the petitioner under the Standing Order - Without holding any enquiry or show cause to the petitioner ¬Whether violative of principles of natural justice? Yes.
D.K. Yadav v. Mis. J.M.A. Industries Ltd., (1993) 3 SCC 259: (1993) 2 LLj 696: (1993) 67 FLR 111: 1993 LLR 584: 1993-I! CLR 116 (SC).

• An employee cannot be thrown out of service by simple notice even if Standing Orders so stipulate.
Uptron India Ltd. v. Shammi Bhan, (1998) 6 SCC 538: A1R 1998 SC 1681: (1998) 1 LLI 1165: (1998) 2 LLN 959: 1998 LLR 385: 1998 (79) FLR 233 (SC).

• Modification of Standing Order - Not included in the schedule to the Act ¬Certifying Officer has no jurisdiction for approval.
IndIa Cement Ltd., Tirunelvli v. Labour Court Madurai, 1994 LLR 277 (Mad HC).

• Model Standing Orders - Extent of applicability - Transfer of petitioner from Kanpur to Calcutta - Being sought to be justified on the basis of provision contained in the Model Standing Orders - No provision of transfer exists in Standing Orders of the Corporation - Held, impugned order not justified.
Sompal Singh v. Artificial Limbs Manufacturing Corporation of Indill, 1994 LLR 152: 1995-1 LLI 81 (All HC).

• Certified Standing Orders do not have statutory force but certainly bind both employers and employees.
Rajasthan State Road Transport Corporation, v. Krishna Kant, 1994 Supp (1) SCC 268: (1994) 26 ATC 841: 1995 LLR 481: 1994(68) FLR 105: 1994-1 LLI 136 (SC).

• Provisions of certified Standing Orders for termination of a permanent employee by one month's notice will be ultra vires.
Vindhyachal Vrihat Tap Vidyut Karamchari 5rmgh (INTUC) v. General Manager, 1995 LLR 813: 1995-11 CLR 950 (MP HC).
Industrial Employment (Standing Orders) Act, 1946 & Conditions of Service     441

• A certifying officer under Industrial Employment (Standing Orders) Act cannot modify the settlement arrived before the conciliation officer.
Bharat Electronics Ltd. v. Chief Labour Commissioner, 1996 LLR 200: 1996-11 LLJ 193 (Del HC).

• Provision for representation by an office-bearer of a trade union in Standing Orders for certification will be mandatory.
Maharashtra General Kamgar Union v. Bharat Petroleum Corporation Ltd., 1996 LLR 900: 1996-11 CLR 544: 1996-11 LLN 571 (Born HC).

• Fairness and reasonableness of Standing Orders for certification cannot be questioned in writ petition.
Maharashtra General Karngar Union v. Bharat Petroleum Corporation Ltd., 1996 LLR 900: ¬1996-11 CLR 544: 1996-11 LLN 571 (Born HC).

• Provision for misconduct for an act outside the premises for certification of Standing Orders cannot be interferred by the certifying officer.
Maharashfra General Kamgar Union v. Bharat Petroleum Corporation Ltd., 1996 LLR 900: 1996-11 CLR 544: 1996-11 LLN 571 (Born HC).

• The certifying officer should consider and weigh social interest while certifying the Standing Orders.
Maharashtra General Kamgar Union v. Bharat Petroleum Corporation Ltd., 1996 LLR 900: 1996-11 CLR 544: 1996-II LLN 571 (Born HC).

• In the event of conflict between the provisions of Standing Orders and Factories Act, the latter will prevail.
Maharashtra General Kamgar Union v. Bhnrat Petroleum Corporation Ltd., 1996 LLR 900: 1996-11 CLR 544: 1996-11 LLN 571 (Born HC).

• In the event of conflict between certified Standing Order and Industrial Employment (S.O.) the Factories Act, the latter will prevail.
S.M. Puthran v. Rallies India Ltd., (1998) 80 FLR 129: 1998 LLR 845 (Born HC).

• Provision for transfer of employees anywhere or detaining them for essential services beyond duty hours in the certified Standing Orders of a big organisation cannot held to be arbitrary.
G.A.I.L.'s Employees Association v. The Chief wbour Commissioner, 1996 LLR 986 (Del He). • There cannot be two different sets of Standing Orders in one establishment ¬Reduction of age of retirement from 60-58 will also be permissible.
Cement Corporation Knramclwri Union v. The Deputy Chief Labour Commissioner (Central), 1996 LLR 123 (P&H HC).

• A company of all India character can frame Standing Orders for throughout India for transfer of its employees.
Cement Corporation Kilramachari Union v, The Deputy Chief Labour Commissioner (Centra!), 1996 LLR 123 (P&H He).

• Provisions with regard to 'abandonment of service' in the Standing Order can be modified by the appropriate authority.
Bhamt Electronics Ltd. v, Bhamt Electronics Ltd, Employees Union, (1996) 74 FLR 2147: (1996) 2 CLR 431: (1996) 2 Mah Lj 111: 1997 LLR 58 (Born HC).

• Modification of Standing Order prohibiting the workers from becoming the office-bearers or members of banned political party is permissible.
Bharat Electronics Ltd. v. Bharat Electronics Ltd. Employees Union, (1996) 74 FLR 2147: (1996) 2 CLR 431: (1996) 2 Mah Lj 111: 1997 LLR 58 (Born He).

• Age of superannuation in certification of Standing Orders could be mutually agreed between management and workmen and every workman on reaching the age of superannuation had to retire from service.
P.R.T.e. Workers Union (Regd.! Patiala v. Pepsu Road Transport Corporation Patia/a, 1997-11 LLj 899 (P&H HC).

• Presumption for abandonment of an employee who remains absent for 15 days cannot be drawn by an employee even when the Standing Orders so provide.
Uttar Pradesh State Textile Corporation Spinning Mills, Jhansi through its Chief Executive v. State of Uttar Pradesh, 1997 LLR 390, 1997-11 CLR 621, 1997-11 LLN 1068 (All HC).

• Fixation of retirement age at 60 instead of 58 years by the certifying officer while certifying the Standing Orders will be legal and the High Court will not interfere.
Rashtriya ChemIcal Fertilizers Ltd. v. General Secretary Fel Worker Union, 1997 LLR 654 (Born HC).

• When a particular misconduct is not enumerated in the certified Standing Orders, the management cannot introduce the same either in a circular or a memorandum. The appropriate course will be to seek amendment of the certified Standing Orders to include non-enumerated misconduct.
Tamil Nadu Electricity Board v. Central Organisation of Tamil Nadu Electricity Employees, 1997-11 LLJ 1043 (Mad HC).

• Any action taken by the employer in accordance with the existing Standing Order prima facie cannot be said to be an unfair labour practice and therefore there appears to be no justification for the Industrial Court in passing the impugned order not to retire the employee.
Phoenix .'Y1ilts Ltd. v. Vitha Tanno Nandgaonkar, 1997-11 CLR 1023 (Born HC).

• Reduction of age of superannuation from 55 years to 60 years by the certifying officer under Industrial Employment (Standing Order) Act without hearing the workmen will be null and void.
Bansidhar Sarna v. Certifying Officer and l.Jlbour Commissioner, Assam at Guwahati, 1997 Lab IC 3061 (Gau HC).

• Termination of a Personal Assistant appointed for three months but extended further on the ground of unsaisfactory work will not be justified when the model Standing Orders stipulated that an employee can be on probation for three months only.
V. Subramanian v. Deepak Nitrite Ltd. Bombay, 1997-11 CLR 1157 (Born HC).

• Mentioning of wrong number of the standing order for misconduct will not vitiate the charge-sheet.
V.V.F. Ltd. v. Saroa Shramik Sangh, 1998 LLR 585 (Born HC).

• Termination of a workman for medical unfitness without constituting a Medical Board will be violative of Standing Orders hence illegal.
Managing Director, SAIL, Bhilai Steel Plant, Bhilai v.Industrial Court of Madhya Pradesh and Three Ors., 1998 LLR 819 (MP HC).

• A project for laying down of Railway tracks will be an Industrial establishment under the Industrial Disputes Act.
Lll Mohammad v.Indian Railway Construction Company Ltd., (1999) 1 sec 596: AIR 1999 SC 355, (1999) 1 LLN 663, (1999) 1 LLJ 317, 1999 LLR 100 (SC).

Industrial Employment IStanding Orders) Act, 1946 & Conditions of Service     443

• There will be no illegality in Standing Orders permitting representation of a delinquent employee by fellow workman.
Bharnt Petroleum Corporation Ltd. v. Maharashtra General Knmgar Union, (1999) 1 sec 626:
AIR 1999 SC 40L (1999) 1 LLN 654: (1999) 1 LL) 352: 1999 LLR 180 (SC).

• Prohibiting bank employees to contest public bodies elections will not amount to change in service conditions.
General Manager (Operations) State Bank of India v, State Bank a/India Staff Union, 1999 LLR 402 (SC).

• VRS resulting into reduction of posts will amount to change in conditions of services and hence violative of the Industrial Disputes Act and MRTU & PULP Act.
K.E.C. International Ltd. v. Kamani Employees' Union, (1999) 1 Mah L) 243: 1998 LLR 598 (Born HC).

• An injunction cannot be granted to Pepsi against Coca Cola for furring away its employees.
Pepsi Foods Ltd. v. Bharat Coca-Cola Holdings Pvt. Ltd., 1999 LLR 1027 (Del HC).

• An agreement with an employee not to undertake employment for 12 months after leaving the job will be violative of Contract Act.
Pepsi Foods Ltd. v. Bharat Coca-Cola Holdings Pvt. Ltd., 1999 LLR 1027 (Del HC).

• Withdrawal of bus facility from the workers on the basis of settlement will not be permissible. In this case, the company has discontinued the bus facility to the workers abruptly.
'aysynth Dyechem Ltd. v. Dyes & Chemical Workers Union, (1999) 2 CLR 211: 1999 LLR 988 (Born HC): 1999 (83) FLR 114.

• Allowing passengers on two occasions to travel without ticket will come within the purview of Standing Orders pertaining to dishonesty, fraud, mal-practice, etc. etc.
Mohan wi Mali v. Rajasthan State Road Transport Corporation, 2000 LLR 80 (Raj HC).

• Any service contract or Standing Orders providing for automatic termination due to absence will be illegal.
Ashok Kumar Pandey v. State of Uttar Pradesh, 2000 LLR 200 (All HC).

• Unless a particular misconduct is enumerated in service rules, no punishment can be imposed.
Mathew v. Plantation Corporation of Kerala Ltd., 2000 LLR 1280 (Ker HC).

• Contravention of Model Standing Orders will amount to unfair labour practice.
    R.P. swant v. Bajaj Auto Ltd., 2001 LLR 935 (Born HC).     .

• Termination of an employee after 15 years of service as stipulated in the Standing Orders will be legal.
Harmohinder Singh v. Kharga Canteen, Ambala Cantl, (2001) 5 sec 540: AIR 2001 SC 2681: 2001 LLR 849 (SC).

• The certified Standing Orders providing abandonment of employment when a workman absents for 10 consecutive days will not be legal.
Scooters india Ltd. v. M. Mohammad Yaqub, (2001) 1 SCC 61: AIR 2001 SC 227: 2001 LlC 71: (2001) 1 LLN 67: 2001 LLR 54 (SC).

• Provision for termination of an employee in the Standing Orders cannot be absolute.
Gouranga Acharjee v. Third Industrial Tribunal, West Bengal, (2001) 90 FLR 1008: (2001) 1 CHN 663: 2001 LLR 909 (Cal HC).


• Statutory provisions will prevail over certified Standing Orders. Kamta Prasad v. Presiding Officer, lAbour Court, Gurgaan, 2002 LLR 1047: 2002 LIC 1934: 2002(1) Servo LR 232 (P&H He).

• An outsider can also hold an enquiry when the Standing Orders do not prohibit.
Sandvik Asia Ltd. v. Maruti Mahipati Jagada/e, (2002) 94 FLR 1086: (2002) 2 CLR 1018: 2002 LLR 1138 (Born He).

• Standing Orders will apply to a Master Technician since he is a 'worker' under the Factories Act.
Shiva Anand v. Indian Airlines, 2003 LLR 285: 2002 LIC 3822: 2003 (96) FLR 1010 (Cal He). • Only Labour Court and not the Industrial Tribunal is empowered to interpret the Standing Orders under the Industrial Employment (Standing Orders) Act.
N.D.M.C. v. Mohd. Shamim, 2003 LLR 524: 2003 (97) FLR 155 (Del He).

• Merely stating that the Standing Orders under Industrial Employment (Standing Orders) Act, 1946 are applicable will not entitle the Management to transfer a workman from one place to another.
Usha Workers' Union v. Usha Martin Industries Ltd., 2003 LLR 760 (}har He).

• No second show cause notice is necessary in the absence of any provision nnder the certified Standing Orders.
Ashok Leyland Ltd., Madras v. Presiding Officer, Second Additional LAbour Court, Madras, 2003 LLR 784: 2003-11 LLN 622 (Mad HC).

• When the certified Standing Orders of an industrial establishment provide that for remaining absent unauthorisedly by the workmen for consecutive 10 days, their names will be struck off, the holding of enquiry will not be necessary when repeated opportunities to report for work have been given before striking off their names.
Continental Construction Ltd. v. Workmen of Continental Construction Ltd., 2003 LLR 895: 2003-IlI LLJ 612 (Kam HC).

• Punishment of suspension of an employee, as enumerated in Standing Orders of the Company as "substantiative punishment ", cannot be challenged and as such the employee cannot claim subsistence allowance for the period of suspension which was treated as punishment.
Sri Gangapathy Mills Company Ltd. v. Dy. Commissioner of L1lbOUT, Tirunelveli, 2004 LLR 434 (Mad HC).

• Holding of enquiry in case of long absence of a workman when the Standing Orders provided that the workman will loose his lien if remained absent for a specified period and as the regular enquiries take long time whi.ch causes loss of production and the whole establishment suffers due to absence of couple of workers.
Chhedi Lal Singh v. Presiding Officer, Labour Court, Allahabad, 2004 LLR 198 (All He).

• In an appeal against the order of the Certifying Officer under the Industrial Employment (SO) Act, fixing the age of retirement, the Appellate Authority has no powers to remand it back.
Management of Manipal Power Press, Rep. by its General Manager, Udupi v. Sadananda Droadiga, 2004 LLR 644 (Karn He).

• Standing Orders under the Industrial Employment (Standing Orders) Act, 1946 have no statutory force hence delegation of powers to an officer, as vested in the General Manager, will be legal.
Ajit Kumar Nag v. General Manager (PJ), Indian Oil Corporation Ltd., 2004 LLR 709 (Cal HC).

Industrial Employment (Standing Orders) Act, 1946 & Conditions of Service     445

• The definition "General Manager" would also include a General Manager In¬charge for the time being and will be competent under the standing orders.
Ajit Kumar Nag v. General Manager (PJ), Indian Oil Corporation Ltd., 2004 LLR 709 (Cal HC).

• When the retirement age has been enhanced from 55 to 58 years by amending the certified Standing Orders, it will not be interfered.
Yuken (India) Ltd. v. The Banga/ore East Industrial Worker's Union, 2005 LLR 326 (Kam HC).

• Reduction of probation period from 9 to 6 months by amending the Standing Orders will not be interfered.
Yuken (India) Ltd. v. The Bangalore East Industrial Worker's Union, 2005 LLR 326 (Karn HC).

• Termination of services of a bus conductor, appointed purely on adhoc basis, governed by the standing orders under the Industrial Employment (Standing Orders) Act was not illegal.
Rajasthan State Road Transport Corporation v. Zakir Hussain, (2005) 7 sec 447: 2005 sec (L&S) 945: (2005) 3 LLN 1048: (2005) 107 FLR 405: 2005 LLR 1044 (SC).

• When a probationer, whose services were terminated, has placed reliance on the standing order under the Industrial Employment (Standing Orders) Act, the only remedy available to him was by way of raising an industrial dispute.
Rajasthan State Road Transport Corporation v. Zakir Hussain, (2005) 7 see 447: 2005 see (L&S) 945: (2005) 3 LLN 1048: (2005) 107 FLR 405: 2005 LLR 1044 (SC).

• When sufficient safeguards are provided in the Standing Orders, the action taken by the General Manager cannot be held arbitrary, or ultra vires.
Ajit Kumar Nag v. General Manager (P'].) v. Indian Oil Corporation Ltd., Haldia, (2005) 7 sec 764: 2005 SCC (L&S) 1020: (2005) 107 FLR 407: 2005 LLR 1137 (SC).

• The modification in providing alternate job, suggested by the Appellate Authority under the Industrial Employment (Standing Orders) Act, would virtually be an amendment hence untenable.
Falcon Tyres Ltd. v. Falcon Tyres Employees' Union, Mysore, 2006 LLR 129 (Kam HC).

• A workman will not be a "permanent employee" under Standing Orders even after six months' satisfactory service,
State of Madhya Pradesh v. Onkar Prasad Patel, (2005) 13 sec 489: (2006) 1 CLR 251: (2006) 1 SLR 407: (2006) 1 LLN I: 2006 LLR 234 (SC).

• A Hospital is neither an industrial establishment nor a workshop as contemplated in section 2(e) of the Industrial Employment (Standing Orders) Act, 1946.
Indraprastha Medical Corporation Ltd. v. National Capital Territory of Delhi, 2006 LLR 628 (Del HC).

• The Model Standing Orders under Industrial Employment (Standing Orders) Act would not apply to an educational institution.
Ram Asrey Yadav and Hindi Sahitya Sammelan Prayag v. The Presiding Officer, lJlbour Court Allahabad, 2006 LLR 595 (All HC).

• Indian Airlines, being covered by Payment of Wages Act, would also be governed by Industrial Employment (S.O.) Act, 1946.
Indian Airlines v. Union of India, 2006 LLR (SN) 766 (Del HC).


• If a particular misconduct is not enumerated in Certified Standing Orders, then the disciplinary proceedings wiil not be valid. Manager, Public and Industrial Relations, Nuclear Power Corporation v. P. Chinnasamy, 2006 LLR 822 (Mad HC).

• Removal of a workman for contracting second marriage during life-time of first wife has been rightly set aside since it is not one of the misconducts in Certified Standing Orders.
Manager, Public and Industrial Relations, Nuclear Power Corporation v. P. Chinnasamy, 2006 LLR 822 (Mad He).

• Labour Commissioner is not empowered to raise the age of retirement when certified Standing Orders are not amended.
Management of Mis. Steelworth Pvt. Ltd. v. State of Assam, 2006 LLR (SN) 1280 (Gau HC). • Industrial Employment (SO) Act wiil not apply to a Post Office hence staying of transfer of Sub Post Master is liable to be set aside.
Union of India v. Kantilal Ratilai Dhakan, 2006 LLR (SN) 1278 (Guj HC).

• Modification of Standing Orders providing inter-establishment transfer is to be set•aside.
Divgi Metal Wares Employees' Associntjrm, Sirsi v. Divgi Metal Wares Ltd., Sirsi, 2007 LLR 42 (Karn HC).

• Certified Standing Orders will not over-ride service conditions in the appointment leller.
Arifa Nauman v. Government of National Capital Territory of Delhi, 2007 LLR 127 (Del He). • No punishment can be imposed for misconduct, not enumerated in the Standing Orders.
Management of Madura Cement (Pvt.) Ltd., Manamadurai v. Presiding Officer, Principal Uibour Court, Madurai, 2007 LLR 130 (Mad HC).

• When the terms and conditions of service in appointment letter are inconsistent with standing orders, the iatter will prevail.
R.P. Garg v. Indian Oil Corporation Ltd., 2007 LLR 247 (Ail He).

• Industrial Employment (SO) Act read with Model Cujarat Rules, 1959 providing 60 years as superannuation age, the retirement of a workman at 58 is rightly quashed.
Ambalal Sarabhai Enterprises Information Service v. Arvind Kumar D. Parekh, 2007 LLR (SN) 440 (Guj He).

• A union, aggrieved by the order of the Authority under the Industrial Employment (5.0.) Act, can file appeal and not the writ petition.
B.P.L. Display Devices Workers Union v. Deputy Labour Commissioner, Ghaziabad, 2007 LLR 554 (SN) (Ail He).

• The object of Standing Orders is to control the internal business in the industriat establishment.
Management of Kiiply Industries Ltd. v. Presiding Officer, UiOOur Court, Dibrugarh, 2007 LLR 1073 (Gau HC).

• A Certifying Officer cannot suo moto review or cancel the certification of Standing Orders.
Muthoot Pappachan Consultancy & Management Services v. Labour Commissioner, 2008 LLR 375 (Ke, HC).

• Amending certified standing orders by restricting suspension of a workman upto four days will curtail freedom of the Management.
West Coast Industrial Gases Ltd. v. Regional Labour Commissioner, 2008 LLR 539 (Ker He). • An apprentice or a probationer will be a 'workman' under the IE (Standing Orders) Act.
Muthoot Pappachan Consultancy & Management Services v. lilbour Commissioner, 2008 LLR 375 (Kef HC).

• When the Industrial Employment (Standing Orders) Act is applicable for enquiry, the dispute will fan under Industrial Dispute Act.
Chief Engineer, Hydel Project v. Ravinder Nath, 2008 LLR 337 (SC).

• Canteen workers not being employees of Management, Standing Orders will not apply.
Management of Tamil Nadu Newsprint and Paper Mills, Pugalur v. Workmen of Tamil Nadu Newsprint and Paper Mills (Represented by Secretary), 2008 LLR 1104 (Mad HC).