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FACULTY OF LAW

JAMIA MILLIA ISLAMIA


Labour Law

Strikes and Lock outs

Submitted By:-
ACKNOWLEDGEMENT

I would like to thank my teacher PROF(DR). N.P.Khan for being a great teacher and for giving me
support and guidance regarding this assignment. . I would also like to thank my friends and peers
for their encouragement throughout the making of this assignment.

Anilesh Tewari

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Table of Contents

 Introduction

 Implications

 Relevant Sections of The Industrial Disputes Act, 1947

 Strike

 Ingredients of Strike

 Position in India

 Provisions of valid Strike

 Notice of Strike

 General prohibition of Strike

 Consequence if illegal strike

 Lock-outs

 Prohibition of Lock-out

 Conclusion

 Bibliography

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Introduction

Every right comes with its own duties. Most powerful rights have more duties attached to them.
Today, in each country of globe whether it is democratic, capitalist, socialist, give right to strike to
the workers. But this right must be the weapon of last resort because if this right is misused, it will
create a problem in the production and financial profit of the industry. This would ultimately affect
the economy of the country. Today, most of the countries, especially India, are dependent upon
foreign investment and under these circumstances it is necessary that countries who seeks foreign
investment must keep some safeguard in there respective industrial laws so that there will be no
misuse of right of strike. In India, right to protest is a fundamental right under Article 19 of the
Constitution of India. But right to strike is not a fundamental right but a legal right and with this right
statutory restriction is attached in the industrial dispute Act, 1947.

Strike is collective stoppage of work by work by workmen in order to bring pressure upon those who
depend upon the sale or purchase of the product of work. Because it is an expensive weapon th strike
is generally the labour’s last resort in connection with industrial controversies.

Lockout is a weapon in the hands of the employer, similar to that of strike in the armory of workman
used for compelling persons employed by him to accept his terms and conditions of or affecting
employment. In lockout an employer shuts down his place of business as a result of reprisal, or as an
instrument of coercion or as a mode of exerting pressure upon the employes with a view to dictate his
own terms to them.

Implications
In any Industrial endeavour co-operation of labour and capital is quite essential for its success,
although they have interests contrary to each other. They have different strategies and weapons to
ventilate their grievances and safeguard their interests. These democratic weapons often used by
them are strikes and lock-outs. Just as strike is a weapon available to employees for enforcing their
Industrial demands, a lock-out is a weapon available to the employer to persuade by a coercive
process to see his point of view and to accept his demands. In the struggle between capital and
labour, as the weapon of strike is available to labour and is often used by it, so is the weapon of lock-
out available to the employer and can be used by him.

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Relevant Sections of The Industrial Disputes Act, 1947

Section 22. Prohibition of strikes and lock-outs. - This section applies to the strikes or lockouts in
industries carrying on public utility service. Strike or lockout in this section is not absolutely
prohibited but certain requirements are to be fulfilled by the workmen before resorting to strike or by
the employers before locking out the place of business.

Section 22:

(1) No person employed in a public utility service shall go on strike in breach of contract-

(a) without giving to the employer notice of strike, as herein-after provided, within six weeks before
striking; or

(b) within fourteen days of giving such notice; or

(c) before the expiry of the date of strike specified in any such notice as aforesaid; or

(d) during the pendency of any conciliation proceedings before a conciliation officer and seven days
after the conclusion of such proceedings.

(2) No employer carrying on any public utility service shall lock-out any of his workmen--

(a) without giving them notice of lock-out as hereinafter provided, within six weeks before locking
out; or

(b) within fourteen days of giving such notice; or

(c) before the expiry of the date of lock-out specified in any such notice as aforesaid; or

(d) during the pendency of any conciliation proceedings before a conciliation officer and seven days
after the conclusion of such proceedings.

(3) The notice of lock-out or strike under this section shall not be necessary where there is already in
existence a strike or, as the case may be, lock-out in the public utility service, but the employer shall
send intimation of such lock-out or strike on the day on which it is declared, to such authority as may
be specified by the appropriate Government either generally or for a particular area or for a particular
class of public utility services.

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(4) The notice of strike referred to in sub-section (1) shall be given by such number of persons to
such person or persons and in such manner as may be prescribed.

(5) The notice of lock-out referred to in sub-section (2) shall be given in such manner as may be
prescribed.

(6) If on any day an employer receives from any persons employed by him any such notices as are
referred to in sub-section (1) or gives to any persons employed by him any such notices as are
referred to in sub-section (2), he shall within five days thereof report to the appropriate Government
or to such authority as that Government may prescribe the number of such notices received or given
on that day.

Section 23. General prohibition of strikes and lock-outs-

The prohibition against strikes and lockouts is contained in section 23 is general in nature. It applies
to both public utility and non public utility establishments.

Section 23:No workman who is employed in any industrial establishment shall go on strike in breach
of contract and no employer of any such workman shall declare a lock-out--

(a) during the pendency of conciliation proceedings before a Board and seven days after the
conclusion of such proceedings;

(b) during the pendency of proceedings before:

1.[a Labour Court, Tribunal or National Tribunal] and two months after the conclusion of such
proceedings;

3.[(bb) during the pendency of arbitration proceedings before an arbitrator and two months after the
conclusion of such proceedings, where a notification

has been issued under sub-section (3A) of section 10A;

(c) during any period in which a settlement or award is in operation, in respect of any of the matters
covered by the settlement or award.

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Section 24. Illegal strikes and lock-outs.-

(1) A strike or a lock-out shall be illegal if--

(i) it is commenced or declared in contravention of section 22 or section 23; or

(ii) it is continued in contravention of an order made under sub-section (3) of section 10 1*[or sub-
section (4A) of section 10A].

(2) Where a strike or lock-out in pursuance of an industrial dispute has already commenced and is in
existence at the time of the reference of the dispute to a Board, 1*[an arbitrator, a] 2*[Labour Court,
Tribunal or National Tribunal], the continuance of such strike or lock-out shall not be deemed to be
illegal, provided that such strike or lock-out was not at its commencement in contravention of the
provisions of this Act or the continuance thereof was not prohibited under sub-section (3) of section
10 1*[or sub-section (4A) of section

10A].

(3) A lock-out declared in consequence of an illegal strike or a strike declared in consequence of an


illegal lock-out shall not be deemed to be illegal.

Section 25. Prohibition of financial aid to illegal strikes and lockouts.-

This section prohibits financial aid to illegal strikes and lock-outs. It says that:

Section 25:No person shall knowingly expend or apply any money in direct furtherance of support of
any illegal strike or lock-out.

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Strike
Strike is one of the oldest and the most effective weapons of labour in its struggle with capital for
securing economic justice. The basic strength of a strike lies in the labour’s privilege to quit work
and thus brings a forced readjustment of conditions of employment[5]. It owes its origin to old
English words ‘Striken to go’. In common parlance it means hit, impress, occur to, to quit work on a
trade dispute. The latter meaning is traceable to 1768. Later on it varied to ‘strike of work’. The
composite idea of quitting work or withdrawal of work as a coercive act could be gathered in the use
of word as a verb as well as adjective. The definition and use of the word ‘strike’ has been
undergoing constant transformation around the basic concept of stoppage of work or putting of work
by employees in their economic struggle with capital[6].

The term ‘strike’ has been defined in a wide variety of branches of human knowledge, viz.
etymology, sociology, political economy, law and political science

Strike has been defined in Section 2 (q) of the Industrial Disputes Act as under—
“Strike means a cessation of work by a body of persons employed in any industry acting in
combination, or a concerted refusal, or a refusal under a common understanding, of any number of
persons who are or have been so employed to continue to work or to accept employment.”

The analysis of the definition would show that there are the following essential requirements for the
existence of a strike:

(1) There must be cessation of work.

(2) The cessation of work must be by a body of persons employed in any industry;

(3) The strikers must have been acting in combination;

(4) The strikers must be working in any establishment which can be called industry within the
meaning of Section 2(j); or

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(5) There must be a concerted refusal; or

(6) Refusal under a common understanding of any number of persons who are or have been so
employed to continue to work or to accept employment;

(7) They must stop work for some demands relating to employment, non-employment or the terms of
employment or the conditions of labour of the workmen.

Ingredients of Strike

Cessation of Work:-

This is most significant characteristic of the concept of strike. It has been variedly expressed as
’abandonment’, stoppage’, ‘omission of performance of duties of their posts’, ‘hampering or
reducing normal works’, ‘hindrance to the working or suspension of work, discontinuing the
employment or breaking their contract of service or refusing or failing to return to or resume
employment or refusing or failing to accept engagement for any work which they are usually
employed for. Thus what required for strike is that there must be stoppage of work or there must be
refusal to continue to work or to accept employment by any number of persons employed for the
work but the refusal must be concerted or under a common understanding.The cessation of work may
take any form. It must, however, be temporary and not for ever and it must be voluntary. No duration
can be fixed for this. If the cessation of work is as a result of renunciation of work or relinquishment
of the strikers’ status or relationship, it is not strike. Permanent cessation of work would result in
termination of the contract of work which is alien to the underlying sanction of strike retaining
contractual relationship during the strike periods. Cessation of work is not a cessation of contract of
employment.

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Concerted action

Another important ingredient of the strike is a concerted action. The workers must act under a
common understanding. The cessation of work by a body of persons employed in any industry in
combination is a strike. Thus in a strike it must be proved that there was cessation of work or
stoppage of work under a common understanding or it was a concerted action of the workers or there
was cessation of work by workers acting in combination. Stoppage of work by workers individually
does not amount to strike. the concerted refusal or refusal under a common understanding to continue
to work or to accept employment or to resume work by any number of persons is a strike. One thing
must be kept in mind that the refusal of work means refusal to perform duties which the workers are
required to perform. If the workers are at liberty to do a particular work or not to do a work their
refusal to work does not amount to strike. For example, over-time work, if it is the duty or workers to
do overtime work necessarily because it is the practice of that establishment to take overtime work
from the workers in that case refusal to work overtime would amount to strike otherwise not. Thus
the test to determine whether refusal to do overtime work constitutes a strike or not would depend
upon whether overtime was habitually worked in that industry.[8]

The strike is illegal

1. if it is in breach of Contract of Employment.


2. if it is in Public Utility Services.
3. if Notice under Section 22(1) is not given.
4. if commenced during Award or settlement period.
5. if commenced During or within 7 days of completion of Conciliation Proceedings.
6. if commenced During or within Two months of completion of Adjudication Proceedings.

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Position in India

In India unlike America right to strike is not expressly recognized by the law. The trade union Act,
1926 for the first time provided limited right to strike by legalizing certain activities of a registered
trade union in furtherance of a trade dispute which otherwise breach of common economic law. Now
days a right to strike is recognized only to limited extent permissible under the limits laid down by
the law itself, as a legitimate weapon of Trade Unions.

The right to strike in the Indian constitution set up is not absolute right but it flow from the
fundamental right to form union. As every other fundamental right is subject to reasonable
restrictions, the same is also the case to form trade unions to give a call to the workers to go on strike
and the state can impose reasonable restrictions. In the All India Bank Employees Association v.
National Industrial Tribunal1 , the Supreme Court held,

"the right to strike or right to declare lock out may be controlled or restricted by appropriate
industrial legislation and the validity of such legislation would have to be tested not with
reference to the criteria laid down in clause (4) of article 19 but by totally different
considerations."

Thus, there is a guaranteed fundamental right to form association or Labour unions but there is no
fundamental right to go on strike. Under the Industrial Dispute Act, 1947 the ground and condition
are laid down for the legal strike and if those provisions and conditions are not fulfilled then the
strike will be illegal.

1
1962 AIR 171, 1962 SCR (3) 269

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Provision of valid strike under the Industrial Dispute Act, 1947-

Section 2(q) of said Act defines the term strike, it says, "strike" means a cassation of work by a body
of persons employed in any industry acting in combination, or a concerted refusal, or a refusal, under
a common understanding of any number of persons who are or have been so employed to continue to
work or accept employment. Whenever employees want to go on strike they have to follow the
procedure provided by the Act otherwise there strike deemed to be an illegal strike. Section 22(1) of
the Industrial Dispute Act, 1947 put certain prohibitions on the right to strike. It provides that no
person employed in public utility service shall go on strike in breach of contract:

(a) Without giving to employer notice of strike within six weeks before striking; or
(b) Within fourteen days of giving such notice; or
(c) Before the expiry of the date of strike specified in any such notice as aforesaid; or
(d) During the pendency of any conciliation proceedings before a conciliation officer and seven days
after the conclusion of such proceedings.

It is to be noted that these provisions do not prohibit the workmen from going on strike but require
them to fulfill the condition before going on strike. Further these provisions apply to a public utility
service only. The Industrial Dispute Act, 1947 does not specifically mention as to who goes on strike.
However, the definition of strike itself suggests that the strikers must be persons, employed in any
industry to do work.

Notice of strike

Notice to strike within six weeks before striking is not necessary where there is already lockout in
existence. In Mineral Miner Union vs. Kudremukh Iron Ore Co. Ltd.2, it was held that the
provisions of section 22 are mandatory and the date on which the workmen proposed to go on strike
should be specified in the notice. If meanwhile the date of strike specified in the notice of strike
expires, workmen have to give fresh notice. It may be noted that if a lock out is already in existence

2
(1989) I Lab LJ 227 (Karn).

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and employees want to resort to strike, it is not necessary to give notice as is otherwise required.
In Sadual textile Mills v. Their workmen3 certain workmen struck work as a protest against the lay-
off and the transfer of some workmen from one shift to another without giving four days notice as
required by standing order 23. On these grounds a question arose whether the strike was justified.
The industrial tribunal answered in affirmative. Against this a writ petition was preferred in the High
Court of Rajasthen. Reversing the decision of the Tribunal Justice Wanchooob served:
" ....We are of opinion that what is generally known as a lightning strike like this take place without
notice..... And each worker striking ......(is) guilty of misconduct under the standing orders ........and
liable to be summarily dismissed.....(as)..... the strike cannot be justified at all. "

General prohibition of strike-

The provisions of section 23 are general in nature. It imposes general restrications on declaring strike
in breach of contract in the both public as well as non- public utility services in the following
circumstances mainly: -

(a) During the pendency of conciliation proceedings before a board and till the expiry of 7 days after
the conclusion of such proceedings;

(b) During the pendency and 2 month's after the conclusion of proceedings before a Labour court,
Tribunal or National Tribunal;

(c) During the pendency and 2 months after the conclusion of arbitrator, when a notification has been
issued under sub- section 3 (a) of section 10 A;

(d) During any period in which a settlement or award is in operation in respect of any of the matter
covered by the settlement or award.

The principal object of this section seems to ensure a peaceful atmosphere to enable a conciliation or
adjudication or arbitration proceeding to go on smoothly. This section because of its general nature of

3
(1958) 2 L.L.J. 628 Rajasthen.

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prohibition covers all strikes irrespective of the subject matter of the dispute pending before the
authorities. It is noteworthy that a conciliation proceedings before a conciliation officer is no bar to
strike under section 23.

In the Ballarpur Collieries Co. v. Salim M. Merchant4 it was held that where in a pending
reference neither the employer nor the workmen were taking any part, it was held that section 23 has
no application to the strike declared during the pendency of such reference.

Illegal Strike-

Section 24 provides that a strike in contravention of section 22 and 23is illegal. This section is
reproduced below:

(1) A strike or a lockout shall be illegal if,

(i) It is commenced or declared in contravention of section 22 or section 23; or


(ii) It is continued on contravention of an order made under sub section (3) of section 10 or sub
section (4-A) of section 10-A.

(2) Where a strike or lockout in pursuance of an industrial dispute has already commenced and is in
existence all the time of the reference of the dispute to a board, an arbitrator, a Labour court,
Tribunal or National Tribunal, the continuance of such strike or lockout shall not be deemed to be
illegal;, provided that such strike or lockout was not at its commencement in contravention of the
provision of this Act or the continuance thereof was not prohibited under sub section (3) of section
10 or sub section (4-A) of 10-A.

4
(1967) II LLJ 201 (Pat)

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(3) A strike declared in the consequence of an illegal lockout shall not be deemed to be illegal.

Consequence of illegal Strike

Dismissal of workmen-

In M/S Burn & Co. Ltd. V, Their Workmen5 , it was laid down that mere participation in the strike
would not justify suspension or dismissal of workmen. Where the strike was illegal the Supreme
Court held that in case of illegal strike the only question of practical importance would be the
quantum or kind of punishment. To decide the quantum of punishment a clear distinction has to be
made between violent strikers and peaceful strikers.

In Punjab National Bank v. Their Employees6 , it was held that in the case of strike, the employer
might bar the entry of the strikers within the premises by adopting effective and legitimate method in
that behalf. He may call upon employees to vacate, and, on their refusal to do so, take due steps to
suspend them from employment, proceed to hold proper inquires according to the standing order and
pass proper orders against them subject to the relevant provisions of the Act.

Wages-
In Cropton Greaves Ltd. v. Workmen7, it was held that in order to entitle the workmen to wages for
the period of strike, the strike should be legal and justified. A strike is legal if it does not violate any
provision of the statute. It cannot be said to be unjustified unless the reasons for it are entirely
perverse or unreasonable. Whether particular strike is justified or not is a question of fact, which has
to be judged in the light of the fact and circumstances of each case. The use of force, coercion,
violence or acts of sabotage resorted to by the workmen during the strike period which was legal and
justified would disentitle them to wages for strike period.

5
AIR 1957 SC 38.
6
AIR 1960 SC 160
7
AIR 1978 SC 1489.

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The constitutional bench in Syndicate Bank v. K. Umesh Nayak8 decided the matter , the Supreme
Court held that a strike may be illegal if it contravenes the provision of section 22, 23 or 24 of the
Act or of any other law or the terms of employment depending upon the facts of each case. Similarly,
a strike may be justified or unjustified depending upon several factors such as the service conditions
of the workmen, the nature of demands of the workmen, the cause led to strike, the urgency of the
cause or demands of the workmen, the reasons for not resorting to the dispute resolving machinery
provided by the Act or the contract of employment or the service rules provided for a machinery to
resolve the dispute, resort to strike or lock-out as a direct is prima facie unjustified. This is,
particularly so when the provisions of the law or the contract or the service rules in that behalf are
breached. For then, the action is also illegal.

Right of employer to compensation for loss caused by illegal strike-

In Rothas Industries v. Its Union9 , the Supreme Court held that the remedy for illegal strike has to
be sought exclusively in section 26 of the Act. The award granting compensation to employer for
loss of business though illegal strike is illegal because such compensation is not a dispute within the
meaning of section 2(k) of the Act.

Lock-outs
The use of the term “lock-out” to describe employer's instruments of economic coercion dates back
to 1860 and is younger than its counterparts in the hands of workers, strike by one hundred years.
Formerly the instrument of lock-out was resorted to by an employer or group of employers to ban
union membership: the employers refused employment to workers who did not sign a pledge not to
belong to trade union. later the lock-out was declared generally by a body of employers against a
strike at a particular work by closing all factories until strikers returned to work. India witnessed
lock-out twenty-five years after the "lock-out" was known and used in the arena of labour
management relations in industrially advanced countries. Karnik reports that the first known lock-out

8
(1994) II LLJ 836 (SC)
9
AIR 1976 SC 425

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was declared in 1895 in Budge Budge Jute Mills. Section 2(1) defines the term Lock-out. However,
the present definition is only a mutilated one. The term was originally and correctly defined in the
Trade Dispute Act, 1929. From the definition given in the Trade Dispute Act, the present Act has
taken the present definition but has omitted the words “when such closing, suspension or refusal
occurs in consequences of a dispute and is intended for the purpose of compelling those persons or of
aid in another Employer in compelling persons employed by him to accept terms or condition of, or
affecting employment”.

With the omission of these words, the present definition fails to convey the very concept of Lock-out.
In Sri Ramchandra Spinning Mills v/s State of Madras10, the Madras High Court read the deleted
portion in the definition to interpret the term lock-out. According to the Court, a flood may have
swept away the factory, a fire may have gutted the premises; a convulsion of nature may have sucked
the whole place under ground; still if the place of employment is closed or the work is Suspended or
the Employer refuses to continue to employ his previous workers, there would be a lock out and the
Employer would find himself exposed to the penalties laid down in the Act. Obviously, it shows that
the present definition does not convey the concept of the term lock out.

Lock-out, When Legal

The Act treats strikes and lock-out on the same basis; it treats one as the counter part of the other.
(Mohammed Sumsuddin), the circumstances under which the legislature has banned strike, it has
also at the Same time banned the lock-out. Thus what holds good-bad; legal-illegal, justified
unjustified for strikes, holds the same for the lock-out. As such, the provisions of the Act which
prohibit the strike also prohibits the lock-out.

The object and reasons for which the Lock-out are banned or prohibited are the same for which
strikes are banned or prohibited. As such, lock-out if not in conflict with Section 22 and 23 may be
said to be legal or not legal. Sections 24(1) (iii), 10(3) and 10A (4A) similarly controls the lock-out.
A lock-out in consequence of illegal strike is not deemed to be illegal. But if lock-out is illegal,

10
(1957) ILLJ 90 Mad

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Section 26(2), 27 and 28 will come in operation to deal with the situation. The Act does not lay down
any guidelines to settle the claims arising out of illegal lock-out. The courts, therefore, have adopted
the technique of apportioning the blame between the Employer and employees. This once again
brings to the fore the concept of justifiability of lock-out.

The Statutory Definition

Section 2(1) of the Industrial Disputes Act, 1947 defines “Lock-out” to mean: The temporary closing
of employment or the suspension of work, or the refusal by an employer to continue to employ any
number of persons employed by him[14]. A delineation of the nature of this weapon of industrial
warfare requires description of: (i) the acts which constitute it; (ii) the party who uses it; (iii) the party
against whom it is directed; and (iv) the motive which prompts resort to it.

Prohibition of Lockout

In the similar circumstances the lockout has been prohibited in the public utility service. Section 22
(2) of the Act provides that no employer carrying on any public utility service shall lock out any of
his workmen:

1.Without giving them notice of lockout as hereinafter provided, within six weeks before locking out;
or
2.Within 14 days of giving notice; or

3.Before the expiry of the day of lockout specified in any such notice as aforesaid; or

4.During the pendency of any conciliation proceedings before a Conciliation Officer and seven days
after the conclusion of such proceedings.

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It makes clear that the employer has to comply with the same conditions before he declares lockout
in his industrial establishment which the workmen are required to comply with before they go on
strike. The conditions for both the parties are same.

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Conclusion
The right to strike is not fundamental and absolute right in India in any special and common law,
Whether any undertaking is industry or not. This is a conditional right only available after certain
pre-condition are fulfilled. If the constitution maker had intended to confer on the citizen as a
fundamental right the right to go on strike, they should have expressly said so. On the basis of the
assumption that the right to go on strike has not expressly been conferred under the Article 19(1) (c)
of the Constitution. Further his Lordship also referred to the observation in Corpus Juris Secundum
that the right to strike is a relative right which can be exercised with due regard to the rights of others.
Neither the common law nor the fourteenth Amendment to the federal constitution confers an
absolute right to strike. it was held in the case that the strike as a weapon has to be used sparingly for
redressal of urgent and pressing grievances when no means are available or when available means
have failed to resolve it. It has to be resorted to, to compel the other party to the dispute to see the
justness of the demand. It is not to be utilized to work hardship to the society at large so as to
strengthen the bargaining power. Every dispute between an employer and employee has to take into
consideration the third dimension, viz. the interest of the society as whole.India in the present context
of economic development programmes cannot afford the unqualified right to the workers to strike or
to the employer to lock-out. Compulsory arbitration as an alternative of collective bargaining has
come to stay. The adoption of compulsory arbitration does not, however, necessarily mean denial of
the right to strike or stifling of trade union movement. If the benefits of legislation, settlements and
awards are to reach the individual worker, not only the trade union movement has to be encouraged
and its outlook broadened but the laws have also be suitably tailored. The existing legislation and
Judicial pronouncements lack breadth of vision. Indeed, the statutory definitions of “strike” and
“lock-out” have been rendered worse by a system of interpretation which is devoid of policy-oriented
approach and which lays undue stress on semantics. The discussion of the concepts and definition of
strike has sought to establish

that legalistic consideration has frequently weighed with the court in interpreting and expounding the
said statutory definition: We believe that emphasis on literal interpretation resulted in ignoring the
ordinarily understood connotation of the term “strike” and in encouraging undesirable activity. We
now pass on to acts which constitute strike. Unlike the Industrial Relations Bill, 1978 the three
phrases used in the definition of "strike" in IDA are not qualified by the expression “total” or
“partial”. Further, they do not specifically take into account go-slow. The Courts have accordingly

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excluded go-slow from the purview of “strike”. However, the exclusion of go-slow from the ambit of
"strike" throws them open to the third party suits for damages.

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Bibliography

1. Labour Law and Industrial Law- S.N. Mishra


2. Labour Law- Avtar Singh
3. Handbook of Industrial Law- N.D. Kapoor
4. Labour Law- S.C. Jain
5. Central Law Publications, 25th edition 2010.

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