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Issues: (i) Whether the 1974 settlements governing bonus and other service conditions continued to bind the parties after notices under section 19(2) and section 9A of the Industrial Disputes Act, 1947. (ii) Whether section 11, section 49 and Regulation 58 of the Life Insurance Corporation Act, 1956 could override the settlements arrived at under the Industrial Disputes Act, 1947.
Issue (i): Whether the 1974 settlements governing bonus and other service conditions continued to bind the parties after notices under section 19(2) and section 9A of the Industrial Disputes Act, 1947.
Analysis: A settlement under the Industrial Disputes Act is a binding industrial contract. The notice to terminate does not create a legal vacuum or revive the pre-settlement position. It only ends the statutory bar on fresh dispute raising and opens the way for renegotiation or adjudication. Until a fresh settlement, award, or other lawful substitution comes into existence, the earlier settlement continues to regulate the relationship between the parties.
Conclusion: The 1974 settlements remained operative and binding until displaced by a fresh settlement, award, or valid law.
Issue (ii): Whether section 11, section 49 and Regulation 58 of the Life Insurance Corporation Act, 1956 could override the settlements arrived at under the Industrial Disputes Act, 1947.
Analysis: The Industrial Disputes Act is the special enactment governing industrial disputes between an employer and workmen, while the Life Insurance Corporation Act is a general enactment concerned with nationalisation and management of the Corporation. In the field of industrial disputes, the special law prevails. The powers under the Life Insurance Corporation Act to alter service conditions do not displace settlements protected by the Industrial Disputes Act, and the amended regulation could not defeat the bonus clause of the 1974 settlements.
Conclusion: The settlements under the Industrial Disputes Act prevailed, and the impugned notices and regulation could not take away the bonus rights created by them.
Final Conclusion: The appeal failed, and the workmen's entitlement under the 1974 settlements was upheld; the Corporation was required to act in accordance with those settlements until supersession by a fresh lawful arrangement.
Ratio Decidendi: A settlement under the Industrial Disputes Act, once validly made, continues to govern the parties after notice of termination until replaced by a fresh settlement, award, or other valid legal instrument, and a general statute cannot override that special industrial law in the absence of a clear inconsistent legislative mandate.