Finality of industrial awards and limits on bonus distribution shape the outcome, with only one compensation claim upheld.

An industrial award, once fully adjudicated, retains finality and cannot be reopened in a later reference absent a material change in circumstances; the principle of res judicata was treated as applicable to industrial adjudication, so the earlier wage award bound the parties. Bonus can be granted only where distributable profits are sufficient to justify distribution among all eligible workmen, and an extra bonus for one section was held unsustainable when the available surplus was inadequate. On the employee claims, only compensation for one workman was upheld, while reinstatement and the remaining compensation claims were rejected on the facts and the law then applicable.

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Issues: (i) whether an industrial award could be reopened in a later reference in the absence of any change in circumstances and whether the earlier adjudication bound the parties; (ii) whether an additional bonus could be awarded to a section of employees when the employer's distributable profits were insufficient to justify bonus for all workmen; (iii) whether the appellate tribunal could interfere with the orders relating to reinstatement and compensation of the four employees and whether its conclusions on those claims were sustainable.

Issue (i): whether an industrial award could be reopened in a later reference in the absence of any change in circumstances and whether the earlier adjudication bound the parties.

Analysis: The earlier award on wage structure had been made after full adjudication and the same dispute had not been shown to have been affected by any material change in circumstances. The principle underlying res judicata was held applicable to industrial adjudication, because finality of decisions is necessary to avoid repeated reopening of the same controversy and to promote industrial peace. The absence of an express statutory rule permitting reopening on specified grounds did not justify treating an award as having no continuing force once repudiated under the Act.

Conclusion: The earlier award bound the parties and could not be disturbed on the facts found.

Issue (ii): whether an additional bonus could be awarded to a section of employees when the employer's distributable profits were insufficient to justify bonus for all workmen.

Analysis: Bonus was treated as payable only when the business had sufficient profits to permit distribution among all employees who contributed to those profits. The available surplus was not enough to support a bonus for all workmen across the employer's units, and therefore no legal or equitable basis existed for granting an extra bonus to only one section of employees on the footing of the total profits of the enterprise. Partial payment to a selected group would be inconsistent with the basis of bonus and likely to create inequality and industrial disaffection.

Conclusion: The additional bonus awarded by the appellate tribunal was unsustainable and was set aside.

Issue (iii): whether the appellate tribunal could interfere with the orders relating to reinstatement and compensation of the four employees and whether its conclusions on those claims were sustainable.

Analysis: The appealability of the original refusal of reinstatement depended on the law then in force, and later amendments expanding the concept of retrenchment had no retrospective effect. On the merits, compensation to one employee discharged after medical examination was upheld because the employer had acted without due enquiry. Reinstatement of two employees discharged on account of absence or detention was disallowed because the alleged procedural defects did not justify upsetting the employer's action. Compensation to the fourth employee was also disallowed because the record showed that he had notice of the accusation and had been dealt with after conciliation and enquiry proceedings.

Conclusion: Only the compensation awarded to the first employee was sustained; the remaining reliefs relating to reinstatement and compensation were set aside.

Final Conclusion: The earlier wage award was restored with limited modification, the additional bonus award was rejected, and only the compensation granted to one employee survived, resulting in substantial relief to the employer in the connected appeals.

Ratio Decidendi: An industrial award, once made after full adjudication, attains finality and should not be reopened in the absence of a material change in circumstances, and bonus can be awarded only when profits are sufficient to justify distribution among all eligible workmen.

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