Revisional jurisdiction and remand powers were upheld where the Labour Court's fairness review was found incomplete.

The Labour Court's power under Section 61 of the Madhya Pradesh Industrial Relations Act, 1950 extended to examining the legality and propriety of an employer's order under the standing orders, while the Industrial Court's revisional jurisdiction under Section 66 permitted interference where the Labour Court failed to exercise vested jurisdiction or acted with material irregularity. On the facts, the Industrial Court found the enquiry officer had ignored material evidence and acted unfairly, and it limited itself to setting aside the Labour Court's order and remitting the matter for fresh adjudication without reappreciating evidence. That remand was a valid exercise of jurisdiction, and the High Court was not justified in quashing it under Articles 226 and 227.

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Issues: Whether the Industrial Court acted within its revisional jurisdiction in setting aside the Labour Court's dismissal order and remanding the matter for fresh decision, and whether the High Court was justified in interfering with that remand under Articles 226 and 227 of the Constitution.

Analysis: The Labour Court under Section 61 of the Madhya Pradesh Industrial Relations Act, 1950 was empowered to examine the legality and propriety of an employer's order made under the standing orders, which conferred a wider jurisdiction than a narrow revisional review. The Industrial Court, in revision under Section 66 of that Act, could interfere where the Labour Court failed to exercise jurisdiction vested in it or acted with material irregularity. On the facts, the Industrial Court found that the enquiry officer had ignored material evidence, approached the matter unfairly, and recorded conclusions that were neither fair nor reasonable. Its order was confined to setting aside the Labour Court's decision and remitting the matter for fresh adjudication, without reappraising evidence. The High Court misread the scope of the Labour Court's power and treated the Industrial Court's interference as impermissible, though the remand order was a just exercise of jurisdiction.

Conclusion: The Industrial Court's remand was valid and within jurisdiction, and the High Court was not justified in quashing it.

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