Labour Court jurisdiction ends after award enforceability; ex parte award cannot be set aside once thirty days from publication lapse.

Under the Industrial Disputes Act, an award becomes enforceable on the expiry of thirty days from publication under Section 17A, and the Labour Court retains jurisdiction to entertain an application to set aside an ex parte award only until that point. Once the award becomes enforceable, the adjudicatory authority is functus officio and cannot reopen the matter. The later authority cited by the appellant was read as recognising only this limited jurisdictional window. On that basis, the Labour Court had no power to set aside the ex parte award after thirty days, and the challenge failed.

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Issues: Whether the Labour Court retained jurisdiction to set aside an ex parte award after the expiry of thirty days from publication of the award.

Analysis: Industrial adjudication under the Industrial Disputes Act, 1947 is subject to the statutory scheme governing enforcement of awards. An award becomes enforceable under Section 17A on the expiry of thirty days from its publication. Until that stage, the Tribunal or Labour Court retains jurisdiction over the reference and may entertain an application to set aside an ex parte award. Once the award becomes enforceable, the adjudicatory authority becomes functus officio. The earlier authorities relied upon were understood as recognising only this limited jurisdictional window, and no contrary rule was found in the later decision cited by the appellant.

Conclusion: The Labour Court could not set aside the ex parte award after the expiry of thirty days from publication; the challenge to the Labour Court's order therefore failed.

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