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Issues: Whether Mazagaon Dock Limited was an industry carried on by or under the authority of the Central Government so that the State Conciliation Officer lacked jurisdiction under the Industrial Disputes Act, 1947.
Analysis: The expression "carried on by or under the authority of the Central Government" was read as referring to industries conducted directly under Central Government authority, not merely industries in which the Central Government held the entire share capital or exercised substantial control through the company's articles. A company incorporated under the Companies Act remains an independent legal entity, and its business is carried on through its own constitution, directors, and corporate mechanisms. Mere ownership of shares by the Central Government, coupled with power to appoint directors or issue directions under the articles, did not convert the company's business into a government industry or make its employees servants of the Government.
Conclusion: The industry was not carried on by or under the authority of the Central Government, and the petitioners were not entitled to the writ or directions sought.
Ratio Decidendi: A commercially incorporated company does not become an industry carried on by or under the authority of the Central Government merely because the Government owns all its shares or exercises control through its articles; the authority contemplated by Section 2(a)(i) requires direct governmental carrying on of the industry.