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Issues: Whether an order passed by a quasi-judicial authority refusing approval under the proviso to Section 33(2) of the Industrial Disputes Act, 1947, was void for want of reasons on the face of the order.
Analysis: The order impugned before the Court was made in the exercise of a quasi-judicial power. The High Court had held that such power could not be validly exercised unless the order disclosed reasons. The Court agreed with that proposition and held that the order refusing approval, having recorded no reasons, was bad. The subsequent settlement between the parties rendered the dispute academic, but it did not affect the legal position on the validity of the order.
Conclusion: The order was invalid because a quasi-judicial authority was required to pass a speaking order containing reasons.
Final Conclusion: The appeal failed and the impugned order could not be sustained.
Ratio Decidendi: A quasi-judicial order must disclose reasons on its face, and an order made without reasons is vitiated.