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Issues: Whether "retrenchment" in section 2(00) of the Industrial Disputes Act, 1947 means only discharge of surplus labour in a continuing undertaking, or whether it covers termination by the employer for any reason whatsoever except the express exclusions in the definition.
Analysis: The definition in section 2(00) was construed in the setting of the Act as a whole, with emphasis on the words "for any reason whatsoever" and the express exclusions in the definition. Earlier decisions restricting retrenchment to surplus labour in a continuing industry were examined, as were later decisions applying the wider reading. The Court reconciled section 2(00) with sections 25F, 25G and 25H by adopting harmonious construction and held that the broader definition was not limited to surplus labour alone. On that construction, terminations by the employer which do not fall within the statutory exclusions are retrenchment, while genuine transfer or closure cases remain governed by the special compensation provisions.
Conclusion: Retrenchment under section 2(00) means termination by the employer of the service of a workman for any reason whatsoever except the categories expressly excluded in the section. The term is not confined to discharge of surplus labour in a continuing industry.
Ratio Decidendi: A statutory definition framed in wide terms must be given effect according to its text and context, and where the legislature expressly excludes only specified categories, all other terminations by the employer fall within the defined expression.