Jurisdiction over industrial dispute reference turns on the appropriate Government, and an incompetent State reference invalidates the award.

An industrial dispute involving an autonomous body constituted under a Central enactment fell within the statutory category for which the Central Government was the appropriate Government. A reference made instead by the State Government was therefore without jurisdiction, and the adjudication founded on that reference was invalid. Because the reference itself was incompetent, the questions whether the body was an industry and whether an employer-employee relationship existed were not examined further. The award based on the invalid reference was set aside, leaving the respondent free to seek a fresh reference from the proper authority.

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Issues: Whether the industrial dispute reference made by the State Government was without jurisdiction because the appropriate Government was the Central Government.

Analysis: The petitioners were constituted under a Central enactment and were treated as an autonomous body under Central control. On that basis, the dispute fell within the category of disputes for which reference had to be made by the Central Government under the statutory definition of appropriate Government. Since the reference was not made by the competent authority, the foundation of the adjudication was held to be invalid. In view of this conclusion, the questions whether the petitioners were an industry and whether an employer-employee relationship existed were not examined further.

Conclusion: The reference made by the State Government was invalid and the resulting award could not stand.

Final Conclusion: The award was set aside and the writ petition succeeded, leaving the respondent free to seek a fresh reference from the proper appropriate Government within the time indicated.

Ratio Decidendi: Where the dispute concerns an autonomous body constituted under a Central enactment and falling within the statutory category governed by the Central Government, a reference made by the State Government is without jurisdiction and any award based on such reference is liable to be quashed.

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