Mandamus in industrial reference matters is limited where Government's refusal rests on a relevant consideration and not an irrelevant one.

A writ of mandamus to compel an industrial reference under Section 10(1) of the Industrial Disputes Act is limited by the administrative nature of the appropriate Government's satisfaction under Sections 10 and 12. The Court does not reappraise the merits of that satisfaction or test the adequacy of the reasons, but may interfere where refusal is based on irrelevant or foreign considerations. On the facts, the Government declined reference because the claimant was treated as a supervisory employee outside the definition of workman, which was a relevant consideration. Mandamus was therefore not warranted and the refusal to refer the dispute was upheld.

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Issues: Whether a writ of mandamus could compel the appropriate Government to make a reference under Section 10(1) of the Industrial Disputes Act when the Government refused reference on the ground that the appellant was not a workman.

Analysis: The statutory scheme under Sections 10 and 12 of the Industrial Disputes Act leaves the initial decision on reference to the satisfaction of the appropriate Government on consideration of the conciliation report. That decision is administrative, not judicial or quasi-judicial. Judicial review in mandamus is limited: the Court does not sit in appeal over the Government's opinion and does not examine the adequacy of the reasons, though interference may be justified if the refusal rests on irrelevant or foreign considerations. On the facts found, the Government declined reference because the appellant was treated as a supervisory employee outside the definition of workman, which was a relevant basis for its decision.

Conclusion: Mandamus was not warranted, and the refusal to make a reference was upheld against the appellant.

Final Conclusion: The challenge to the Government's refusal of reference failed because the decision was treated as an administrative determination based on a relevant consideration, leaving no ground for judicial compulsion under Article 226.

Ratio Decidendi: A writ of mandamus to compel industrial reference lies only where the appropriate Government's refusal under Sections 10 and 12 of the Industrial Disputes Act is shown to be based on irrelevant or foreign considerations; the Court does not reappraise the merits of the Government's administrative satisfaction.

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