Binding workmen's settlement under the Industrial Disputes Act bars later wage claims despite a procedural omission in claim reasons.

Rule 163 of the Companies (Court) Rules, 1959 requires the Official Liquidator to record reasons when admitting or rejecting a proof of claim, but the omission did not require remand because the dispute could be resolved on the admitted material already on record. A settlement entered into with a workmen's union under section 18(3) of the Industrial Disputes Act, 1947 was binding on a workman who was a union member, had accepted payment under it, and where the settlement was described as full and final and remained unchallenged. The later claim for additional wages from the same employment dispute was therefore barred.

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Issues: (i) Whether non-recording of reasons by the Official Liquidator under the Companies (Court) Rules, 1959 required remand of the claim for fresh consideration; (ii) Whether the settlement arrived at with the workmen's union bound the appellant and barred any further claim for wages.

Issue (i): Whether non-recording of reasons by the Official Liquidator under the Companies (Court) Rules, 1959 required remand of the claim for fresh consideration.

Analysis: The claim was examined in the light of rule 163 of the Companies (Court) Rules, 1959, which requires the Official Liquidator to admit or reject a proof of claim in writing and to state the grounds of rejection when a claim is rejected wholly or in part. The omission to comply with that requirement was noticed, but the Court held that remand was unnecessary because the controversy could be decided on the admitted material already on record.

Conclusion: The procedural lapse did not justify remand.

Issue (ii): Whether the settlement arrived at with the workmen's union bound the appellant and barred any further claim for wages.

Analysis: The appellant was a member of the union that entered into the settlement, had already accepted payment under it, and the settlement described the payment as one in full and final settlement of the workmen's dues. The settlement was in force and had not been challenged in law. A settlement arrived at under section 18(3) of the Industrial Disputes Act, 1947 is binding on the parties to it, and a member of a party union cannot disregard it to pursue an additional wage claim arising from the same employment dispute. On that basis, the Court treated the later claim as barred by the settlement.

Conclusion: The settlement was binding on the appellant and no further claim for wages could be entertained.

Final Conclusion: The challenge to the disallowance of the additional wage claim failed, and the order rejecting the appeal stood affirmed in substance.

Ratio Decidendi: A settlement reached under section 18(3) of the Industrial Disputes Act, 1947 binds a workman who is a member of the party union, and where such settlement is accepted as full and final settlement and remains unchallenged, no additional claim arising from the same dues can be maintained.

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