Industrial dispute reference need only show the dispute and parties with reasonable clarity; detailed specification is not mandatory.

A Government reference under the Industrial Disputes Act is valid where material shows an existing or apprehended industrial dispute, and the court will not invalidate the reference merely because it would assess the material differently. The reference order need not particularise every issue in dispute or set out the parties in detailed terms; it is sufficient if the industrial dispute and the parties are identifiable with reasonable clarity. The Tribunal may then call for pleadings and settle the issues for adjudication. On this approach, the reference was upheld and the challenge to the proceedings failed.

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Issues: (i) Whether an industrial dispute existed or could be apprehended so as to justify the Government's reference under the Industrial Disputes Act, 1947. (ii) Whether a reference under section 10(1)(c) had to specify the particular dispute and the parties in detail.

Issue (i): Whether an industrial dispute existed or could be apprehended so as to justify the Government's reference under the Industrial Disputes Act, 1947.

Analysis: The demands raised by the employees' association and considered in conciliation were common to the cinema industry in Madras and had not been accepted by all employers. The Government had before it material showing a collective labour dispute affecting the industry, and section 10(1)(c) permitted a reference where a dispute existed or was apprehended. The making of a reference is an administrative act, and the court was not entitled to invalidate it merely because it considered the material insufficient in a judicial sense.

Conclusion: The reference was valid and the dispute was sufficient to sustain the Tribunal's jurisdiction.

Issue (ii): Whether a reference under section 10(1)(c) had to specify the particular dispute and the parties in detail.

Analysis: The statute did not require the Government to crystallise the dispute in the order of reference or to set out each contentious point with precision. It was enough that the order showed an industrial dispute of the relevant kind and indicated the parties, individually or collectively, with reasonable clarity. The Act contemplated that the Tribunal would call for statements of case and settle the issues before adjudication, so the absence of detailed specification in the reference did not vitiate the proceedings.

Conclusion: Detailed specification of the dispute in the reference was not mandatory, and the reference could not be struck down on that ground.

Final Conclusion: The High Court's order quashing the criminal proceedings was set aside, and the petition before it failed.

Ratio Decidendi: A Government reference under section 10(1)(c) is valid if an industrial dispute exists or is apprehended and the nature of the dispute and the parties are identifiable with reasonable clarity; the Act does not require the reference order to particularise every issue in dispute.

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