Successor management bound by Labour Court award; private memorandum cannot defeat accrued workmen rights.

The Labour Court award directing reinstatement without back wages remained binding on the successor management, because an award under Section 18(3)(c) of the Industrial Disputes Act binds successors and assigns. The change in management did not extinguish the obligation to implement the award, and the memorandum of understanding between the old and new management could not override or curtail rights already accrued to the workmen under that award. The claim petitions were therefore maintainable against the successor management, and the challenge to them failed.

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Issues: Whether the Labour Court's award and the subsequent claim petitions were binding on the successor management, and whether the memorandum of understanding between the old and new management affected the workmen's rights.

Analysis: The claim petitions arose from the non-implementation of an earlier Labour Court award directing reinstatement of the workmen without back wages. The Court held that under Section 18(3)(c) of the Industrial Disputes Act, 1947, the award bound the successor as well as assigns. The change in management did not relieve the new management of the obligation to comply with the award. The memorandum of understanding entered into between the managements could not override or curtail the rights already accrued to the workmen under the award.

Conclusion: The successor management remained bound by the Labour Court award, the memorandum of understanding had no effect on the workmen's rights, and the challenge to the claim petitions failed.

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