Writ review limits in labour disputes: High Court cannot reappreciate evidence or upset a Labour Court award on jurisdictional facts.

The Supreme Court held that a High Court exercising Article 226 jurisdiction cannot act as an appellate court over a Labour Court award or reappreciate evidence on factual or jurisdictional questions where the tribunal is competent to decide them. The Labour Court's findings that the union had raised a demand and that the termination was illegal, mala fide, and a colourable exercise of power were therefore not open to such interference. Failure of conciliation and the Conciliation Officer's report were sufficient to support the Government's reference of the industrial dispute for adjudication. The High Court's reliance on another authority was misplaced, and the Labour Court's award was restored.

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Issues: Whether the High Court was justified in interfering under Article 226 with the Labour Court's award by reappreciating evidence and by holding that no industrial dispute existed and that the reference was incompetent.

Analysis: The Labour Court had recorded categorical findings that the union had raised a demand before the management and that the termination of the workman's services was illegal, mala fide, and a colourable exercise of power. In writ jurisdiction, the High Court was not entitled to sit as an appellate court over a tribunal constituted under special legislation or to reappraise evidence on questions of fact, including jurisdictional facts, when the tribunal was competent to decide them. The failure of conciliation and the Conciliation Officer's report were sufficient to justify the Government in referring the dispute for adjudication. The authority relied on by the High Court did not govern the present facts.

Conclusion: The High Court was not justified in quashing the Labour Court's award under Article 226, and the award was rightly restored.

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