A CRITICAL SCRUTINY OF POWER OF REVIEW OF

LABOUR COURTS UNDER IDA 1947 AND CODE ON IRs 2020

SUBMITTED BY SUPERVISED BY

SUJIT KUMAR (72 LLB 18) Dr. JEET SINGH MANN

NATIONAL LAW UNIVERSITY

DELHI

2021
 Table of Contents

 Declaration ………………………………….. 3

 Introduction …………………………………. 4-6

 Chapter 1 ……………………………………. 7-9

 Chapter 2 ……………………………………. 10-14

 Chapter 3 ……………………………………. 15-16

 Conclusion …………………………………... 17

 Bibliography ………………………………… 18-19

 DECLARATION

I hereby declare that the work reported in the research paper entitled
“A Critical Scrutiny of Power of Review of Labour Courts Under
IDA 1947 and Code on IRs 2020” submitted at National Law
University, Delhi is an outcome of work carried out under the
supervision of Dr. Jeet Singh Mann. I have duly acknowledged all
the sources and references from where the ideas have been taken. To
the best of my understanding, the project is free from any plagiarism
issue.

SUJIT KUMAR

National Law University, Delhi

14th May, 2021

 INTRODUCTION

The Industrial Disputes Act, 1947 (hereinafter referred to as “the Act”) was enacted with an
object of promoting industrial peace in the country, to eschew conflicts between the employer
and the workmen and provide for speedy resolution of investigation and settlement of
disputes.1 The Act also aimed at prevention of illegal strikes and lockouts to ensure that the
industrial development and economy of the country is not hampered due to such actions of
the workmen and the employer. 2 In order to adjudicate upon industrial disputes, the act
provides for adjudicatory mechanism by way of labour courts and industrial tribunals. The
jurisdiction of the labour courts or the industrial tribunals kick in by way of reference by the
appropriate government under the existence or the apprehension of an industrial dispute or by
way of direct route under section 2A of the act. Once an award is made by the labour court or
industrial tribunal, the same becomes functus officio after 30 days of the publication of award
under section 17A. The labour courts or the tribunals under the act have not been empowered
to review their award on merits once the award becomes enforceable under section 17A and
is therefore precluded from modifying or altering the award once made. Any power regarding
modification or alteration of the award is vested with the appropriate government under
section 17A. The Industrial Relations Code, 2020 also on the other hand does not contain any
provision regarding review of the award.

It is argued through this research paper that there is a need to empower the labour courts or
tribunals with the power to review their decision on merits. This will also go on ensuring that
any error apparent on the face of the record is resolved at the same forum itself and reduce
the pendency upon the High Courts and the Supreme Court. At present, from the decisions of
the labour courts or the tribunals, an appeal lies before the division bench of the High Court
and then to Supreme Court under article 136. This goes on to the stockpiling of cases before
the constitutional courts and defeat the very purpose of the creation of labour courts or
tribunals which were aimed at reducing the burden upon the High Courts and the Supreme
Court. Another plausible argument in favour of power of review to the labour courts or
industrial tribunals is that the parties generally use the power of appeal as delaying tactic for

1
Workmen of Dimakuchi Tea Estate v The Management of Dimakuchi Tea Estate, AIR 1958 SC 353, para. 15
2
Ibid.
the enforcement of award. Hence, the power of review will help in quick disposal of the case
before the same forum and also enable quick enforcement of the award. The process of
appeal and its adjudication generally takes longer duration which may be cumbersome for the
parties and have a detrimental effect upon industrial development and economy and hence,
there is a greater need to empower the labour courts or tribunals with the power of review.

Literature Review

The primary sources for the formulation of the research paper are the case laws. The case of
Grindlays Bank Ltd. v Central Government Industrial Tribunal and Ors. is of prime
importance as it neatly distinguishes between the procedural review and the review on merits
and lays the foundation for the review jurisprudence of the labour legislations. The recent
judgement of Haryana Suraj Malting Ltd. v Phool Chand is also seminal in nature as it does
away with the strict requirement of filing of an application for procedural review within thirty
days of the publication of award. Other important primary sources are the existing statutes
namely the ID Act and the recently introduced IRs Code 2020 which impliedly talks about
the functus officio nature of the labour courts and the industrial tribunals. Another important
source is the 14th Law Commission Report which talks about the exorbitant rise in labour law
cases before the Supreme Court by way of article 136 and therefore recommends for the
setting up of an appellate labour tribunal along the lines of labour appellate tribunal which
got abolished in 1956.

Hypothesis

The absence of power of review on merits to labour court and the industrial tribunal under the
existing ID Act has led to an overwhelming number of labour law cases reaching directly to
the High Courts and the Supreme Court by way of appeal. Neither the recently introduced
however yet to come into force, the IRs Code provides for such provision. As a result of
which, there has been a steep rise in the pendency of cases before the higher judiciary. Hence,
the power of review to some extent is going to act as a mitigating factor in the existing
miseries of the higher judiciary regarding pendency.
Research Questions

 Whether the labour courts or industrial tribunals are empowered to set aside an ex-
parte order once they become functus officio?

 Whether the power of review on merits to labour courts or industrial tribunals is going
to have an impact upon the existing pendency before the higher judiciary?

Research Methodology

The research methodology is doctrinal in nature and the method is descriptive.

Research Scheme

The research paper is divided into three chapters namely:

 Review- Meaning, Object and Scope.

 Power of Review under ID Act 1947 and IRs Code 2020.
 Power of Review and Pendency before High Courts and Supreme Court.
 CHAPTER I

REVIEW- MEANING, OBJECT AND SCOPE

 Meaning

Before delving deep into the topic, it is pertinent to understand the meaning of the word
review. The Merriam Webster’s Dictionary3 defines the word review as “to study or look at
(something) again”. As per Black’s Law Dictionary4 review means “consideration,
inspection, or re-examination of a subject or a thing”. Similarly, P Ramanatha Aiyar’s5
defines review as “a proceeding which exists by virtue of a statute, it is in its nature a new
trial of the issue previously tried between the parties, the cause of action being brought into
Court again for trial by a new petition”.

The Punjab and Haryana High Court in the case of Parduman Singh v State of Punjab6 has
explained review as a process under which the courts relook their retrospective actions and
does a judicial re-examination of the decisions made in the past. The proceedings under a
review process are generally to reconsider its own judgement. Similarly, in the case of Lily
Thomas v UOI7, it was held that review is an act of looking at something again with an aim to
seek correction or improvement. Hence, from the aforementioned definitions and
interpretation, a review would mean a re-evaluation of one’s judgement or decision.

 Object

The object behind entrusting the courts or tribunals with the power of review has been
discussed in a catena of judgements including S. Nagaraj v. State of Karnataka8 wherein the
Supreme Court opined that the power of review would literally mean reconsideration or re-
examination. The judgement also made it unequivocally clear that the power of review cannot
be exercised to disturb the final outcome but only to remove a glaring error apparent on the
3
https://www.merriam-webster.com/dictionary/review
4
Black’s Law Dictionary, (10th edn, 2014) p. 1514
5
P Ramantha Aiyar’s, ‘The Law Lexicon’ (3rd edn, 2012) p. 1589
6
Parduman Singh v State of Punjab, AIR 1958 P&H 63
7
Lily Thomas v UOI, (2000) 6 SCC 224
8
S. Nagaraj v. State of Karnataka, (1993) 4 SCC 595
face of record.9 The power of review has been statutorily or judicially incorporated to correct
clerical or accidental errors and to prevent miscarriage of justice. The fundamental reasoning
behind granting the courts or tribunals with the power of review is to accept human fallibility
and human nature which is prone to making mistakes.10

The purpose behind the review is very well in sync with the well-known maxim actus curiae
neminem gravabit which means an act of the court shall prejudice no one. Hence, to correct
or rectify any error made by the courts, the courts would be very well empowered to review
their decisions to prevent miscarriage of justice.11 The courts therefore, under the power of
review can go to an extent of even altering, modifying or overturning the decision earlier
made.

 Scope

The provisions relating review are contained under section 114 and order XLVII of the Code
of Civil Procedure. The scope of the powers under review is not absolute and is
circumscribed by Order XLVII Rule 1 of CPC. Under Order XLVII Rule 1, an application for
review against a judgement can be made upon the discovery of new matter or evidence which
was not within one’s knowledge even after the exercise of due diligence or such matter or
evidence could not be produced at the time when the order or decree was passed against such
person.12 Another ground upon which the powers relating to review can be exercised is where
there is a mistake or error apparent on the face of record. 13 An application for review is also
available when there is any other sufficient reason for exercise of power of review. Further,
the explanation to Rule 1 states that simply because the decision on a question of law has
been reversed or modified by the superior court will not be any ground for the review of a
judgement.14 In the absence of any sufficient ground, the court reserves the right to cancel
such application for review under rule 4.15

9
Ibid. para 12
10
S.G. Prashanth Murthy, ‘Power to Review Arbitral Awards- Boon or a Bane?’ (2020) 6 SCC J-27
11
Food Coporation of India v SEIL Ltd., (2008) 3 SCC 440
12
Code of Civil Procedure, Order XLVII Rule 1
13
Ibid
14
Ibid
15
Ibid
The contours of powers exercisable under review have been clarified by the Supreme Court.
In the case of State of Orissa v Commr. Of Land Records and Settlement, 16 the court held that
the scope of review is very limited and narrow and the error sought to be rectified by way of
review must be glaring and self-evident which does not require any detailed argumentation or
examination. In the case of Parsion Devi v Sumitri Devi17, the court held that review cannot
take place even if the judgement is erroneous and the scope of review has to be construed
narrowly and shall be confined to the provisions of particular statute. It can only take place
when there is an error apparent on face of the record. Review also cannot be supplanted with
original hearing of the case. The same view has been reiterated in the case of Ajit Kumar
Rath v State of Orissa and Ors. 18 In the case of Inderchand Jain v Motilal,19 the court
clarified upon the difference between appeal and review and stated that the review court
cannot sit in appeal over its own order.

16
State of Orissa v Commr. Of Land Records and Settlement, (1998) 7 SCC 162
17
Parsion Devi v Sumitri Devi, (1997) 8 SCC 715
18
Ajit Kumar Rath v State of Orissa and Ors., (1999) 9 SCC 596
19
Inderchand Jain v Motilal, (2009) 14 SCC 663
 CHAPTER II

POWER OF REVIEW UNDER ID ACT, 1947 AND IRs CODE,

2020

The law relating to exercise of power of review by quasi-judicial authorities or the tribunals
have been delineated in numerous judgements. It has been held by the Supreme Court in the
cases of Dr. (Smt) Kuntesh Gupta v Management of Hindu Kanya Maha Vidyalaya, Sitapur
(U.P.) and Ors.20 and Patel Narshi Thakershi and Ors. v Pradyumansingh Arjunsingji 21 that
the power of review is not an inherent power and the same must be conferred either by a
statute expressly or by necessary implication. The same viewpoint has been reiterated in the
case of Grindlays Bank Ltd. v Central Government Industrial Tribunal and Ors. 22 and Kapra
Mazdoor Ekta Union v Management of Birla Cotton Spinning and Weaving Mills Ltd. and
Ors.23 wherein the matter was brought under Industrial Disputes Act, 1947.

Hence, from the above-mentioned case laws it is clear that the power of review can be
exercised only when such a power is conferred expressly or is derived by way of necessary
implication. Now, if we analyse the provisions of both ID Act and the IRs Code, we find that
there is no such provision granting the labour courts or the tribunals with the power of
review. The labour courts or the tribunals are precluded from recalling their award once made
and therefore cannot alter or modify the award made. The labour courts and the tribunals
under section 17A of the ID Act becomes functus officio after thirty days of the publication of
award or when the award becomes enforceable. 24 Similarly, under section 55 of the IRs Code
the tribunal becomes functus officio after the communication of the award to parties. 25
Therefore, after becoming functus officio the labour courts or tribunals, both under ID Act
and the IRs Code cannot alter or modify the award or review the same. The power to reject,
alter or modify the award vests only with the appropriate government on public grounds

20
Dr. (Smt) Kuntesh Gupta v Management of Hindu Kanya Maha Vidyalaya, Sitapur (U.P.) and Ors., (1987) 4
SCC 525
21
Patel Narshi Thakershi and Ors. v Pradyumansingh Arjunsingji, AIR 1970 SC 1273
22
Grindlays Bank Ltd. v Central Government Industrial Tribunal and Ors., AIR 1981 SC 606
23
Kapra Mazdoor Ekta Union v Management of Birla Cotton Spinning and Weaving Mills Ltd. and Ors., (2005)
13 SCC 777
24
Industrial Disputes Act 1947, sec. 17A
25
Industrial Relations Code 2020, sec. 55
affecting national economy or social justice under section 17A(1)26 and section 55(3)27 of the
IRs Code respectively. The word review however, does find a mention under both the ID Act
as well as the IRs Code 2020 but a such a power is only accorded to the appropriate
government under which the appropriate government can review its decision regarding grant
or refusal to grant permission pertaining to lay-off, retrenchment and closing down an
undertaking or industrial establishment.28

Procedural Review vis-à-vis Review on Merits (Substantive Review)

The leading judgement delineating upon the power of review to be exercised by labour courts
or tribunals is the Grindlays Bank Ltd.v Central Government Industrial Tribunal and Ors.
The Supreme Court in this case differentiated between the procedural review and review on
merits and stated that the procedural review is either inherent or implied in every court or
tribunal and it is only the review on merits where the error is apparent on the face of record
and the award sought to be altered or modified pertains to an interpretation of question of law
which is prohibited unless the same is conferred expressly by the statute or is derived by way
of necessary implication.29 The court further held that seeking a review on grounds of
procedural defect must be entertained and corrected ex debito justitiae to prevent abuse of
process and miscarriage of justice.30

In this case, the court was confronted with the question of setting aside an ex-parte order
made by the industrial tribunal. It was contented by the party that since the ex-parte award
was based on evidence, setting aside such an award would virtually amount to review which
the tribunal was not empowered under the ID Act. The court negatived such a contention by
stating that the tribunal was very much empowered to set aside the ex-parte order as the
tribunals are vested with such incidental or ancillary powers to do justice between the parties
despite the absence of any express provision empowering the tribunal to do so. 31 The court
buttressed this argument by referring to section 11(1) and section 11(3) of the act which talks
26
ID Act, sec. 17A(1)

27
IRs Code 2020, sec. 55(3)
28
ID Act, sec 25M(7), 25N (6), 25O(5) and IRs Code, sec 78(7), 79(6), 80(5)
29
Grindlays Bank Ltd. v Central Government Industrial Tribunal and Ors., AIR 1981 SC 606, para 13
30
Ibid.
31
Ibid. para 6
about procedures and powers of the authorities under the ID Act.32 Section 11(1) empowers
the authorities under the ID Act to devise or follow such procedure as they think fit subject to
the rules made under the act. Rule 22 of the Industrial Disputes (Central Rules), 1957 framed
by the Central Government under section 38 of the act regulates the procedure regarding
passing of an ex-parte order on sufficient cause not being shown. 33 Therefore, if a party is
able to show sufficient cause for the non-appearance at the time of hearing, the ex-parte
award will be liable to be set aside. The clauses (a) to (c) of the section 11(3) vests with the
tribunal and other authorities the same powers as are vested in civil courts regarding
compelling the attendance of any person and examining him on oath, compelling the
production of document, examination of witnesses.34 Hence, the court held that the question
of giving a hearing to the party before he is proceeded with is one of procedure and not
power.35 The tribunals or other authorities under the act have the trappings of the court and
exercise quasi-judicial functions. The court therefore, held that since the procedural
requirement on part of the quasi-judicial authorities is to act in accordance with the principles
of natural justice, any such procedural violations like not giving hearing to the other side will
make the award a nullity.36 The court further held that an ex-parte award never gains finality
and is liable to be set aside on sufficient cause being shown. 37 Hence, the court unequivocally
stated that the procedural review is always available before a labour court or industrial
tribunal under the ID Act.

The other issue which the court addressed in this case was regarding the time period within
which an application for seeking procedural review can be filed. It was argued that the labour
court becomes functus officio after making the award. The court rejected such an argument by
referring to section 20(3) of act which states that the proceedings before the tribunal deem to
continue till the date on which the award becomes enforceable that is after thirty days of the
publication of such award under section 17. 38 The jurisdiction of the tribunal or the labour
courts remain intact until the expiry of thirty days from publication. 39 Thus, the court held
that any such application for procedural review can be made within thirty days of the
publication of the award.
32
Ibid. para 7
33
ID Act, sec 11(1)
34
ID Act, sec 11(3)
35
Grindlays Bank, supra note 27, para 13
36
Grindlays Bank, supra note 27, para 10
37
Grindlays Bank, supra note 27, para 14
38
Ibid, para 14
39
Ibid
In the case of Kapra Mazdoor Ekta Union v Management of Birla Cotton Spinning and
Weaving Mills Ltd. and Ors., the recall of the order was being sought on merits. The court
reiterated the position laid down in earlier judgements and held that a review on merits can
take place only if such powers are given by way of express provision or is derived by way of
necessary implication.40 It also laid down the distinction between procedural review and
review on merits and stated that under a procedural review, the authority adjudicating over a
dispute is only concerned with correcting the procedural illegality which permeates deep into
the matter and invalidates the entire proceeding. 41 Hence, a hearing where no notice has been
given to other party or the other party was prevented from hearing due to sufficient cause, the
courts can very well invoke their power of procedural review to do justice between the
parties.

The Supreme Court followed the decision of the Grindlays Bank in the case of Anil Sood v
Presiding Officer, Labour Court II42 and held that the labour court does not immediately
becomes functus officio after the making of an award and any award made without giving
hearing to the party is a nullity, therefore the labour courts or the industrial tribunals reserve
their right to set aside any ex-parte order on sufficient cause being shown as per the mandate
of Rule 22 of the Industrial Disputes (Central Rules), 1957.43

The issue regarding time limit for seeking procedural review has been crystallized in the
recent judgement of Haryana Suraj Malting Ltd. v Phool Chand. 44 In this case also, the court
was confronted with the question of setting aside an ex-parte order. The court held that any
award made in violation of the procedural requirement of acting in accordance with the
principles of natural justice is a nullity and therefore can be set aside at any point of time. 45
For an award to be binding, the same must not be violative of principles of natural justice.
The court further held that the labour court or the tribunal does not become functus officio
after the award becomes enforceable and it is very much within its jurisdiction to entertain an
application for procedural review to set aside an ex-parte award as per the scheme of the act

40
Kapra Mazdoor, supra note 21, para 19
41
Ibid
42
Anil Sood v Presiding Officer, Labour Court II, (2001) 10 SCC 534
43
Ibid. para 7
44
Haryana Suraj Malting Ltd. v Phool Chand, (2018) 16 SCC 567
45
Ibid. para 35
and rules of natural justice.46 Finally, it was held that the ID Act is a welfare legislation
intended at maintaining industrial peace and therefore the labour court or the tribunal must be
endowed with such powers to do justice between the parties, whether we call it incidental,
ancillary or inherent.47 Hence, there is no requirement to file a procedural review application
within thirty days of the publication of the award as has been interpreted earlier in the
Grindlays Bank case.

46
Ibid
47
Ibid
 CHAPTER III

POWER OF REVIEW AND PENDENCY BEFORE HIGH

COURTS AND SUPREME COURT

The system of tribunals was devised in our country to tackle the burgeoning pendency of
cases before the lower courts, high courts and the supreme court. Furthermore, with the
increase in specialized and complex subject matters, it became quite difficult for the existing
adjudicatory mechanism to adjudicate as they lacked the requisite technical and specialized
subject matter expertise. The tribunals are quasi-judicial bodies comprised of both judicial as
well as administrative member possessing technical expertise to deal with disputes arising out
of specialized subject matter. The procedure followed by the tribunal system is also less
formal and technical than the court system. The tribunal system finds its origins way back in
the year 1941 with the setting up of Income Tax Appellate Tribunal but a huge fillip to the
tribunal system was provided by way of 42 nd Amendment, 1976.48 The 42nd Amendment
introduced article 323A and 323B to the constitution. The former paves way for the setting up
of administrative tribunals to adjudicate upon service and recruitment related disputes
whereas the latter provides for the setting up of tribunals for other matters.

But unfortunately, the tribunal system has miserably failed to fulfil its mandate of reducing
pendency before the higher judiciary. The ID Act, 1947 is the most important labour law
legislation for the adjudication of labour and industrial disputes. It makes provisions for the
setting up of labour courts and the industrial tribunals. The newly introduced IRs Code on the
other hand dispensed with the system of labour courts and contains provisions only for the
setting up of tribunals. Under both the ID Act as well as the IRs Code, the award or the
judgement of the labour court and the tribunal is accorded finality and there is no provision
regarding appeal from these forums. The appeal from these forums are subject to the special
leave jurisdiction of the Supreme Court under article 136. The majority decision of the
48
Roger Mathew v South India Bank Ltd and Ors., (2020) 6 SCC 1, para 30
Supreme Court in the case of Bharat Bank v Employess of Bharat Bank 49 held that the
decisions of the quasi-judicial authorities would always be subject to appeal under article 136
to ensure judicial control over such bodies.50 Neither the act nor the code has provisions for
the setting up of a central appellate forum to hear appeals from these bodies as a result of
which the appeal directly lies before the supreme court under article 136 of the constitution
by way of special leave. Also, with the 1997 L. Chandra Kumar judgement, the appeal from
the decision of a tribunal now lies directly before the division bench of the High Court. 51 This
has led to inordinate rise of cases relating to labour law before the constitutional courts and is
one of the foremost reasons for the increasing pendency before the High Courts and the
Supreme Court. Apart from direct appeal to the high courts and the supreme court, the
constitutional courts also exercise writ jurisdiction over the tribunals under article 226/227
and article 32 respectively. This again has resulted into huge pendency before the
constitutional courts. The 14th report of the Law Commission dealt extensively with these
issues and suggested for the setting up of central appellate forums to deal with appeals arising
out of the decisions of the labour courts and the industrial tribunals along the lines of Labour
Appellate Tribunal which were established in the year 1950 but got abolished in the year
1956.52

Apart from setting up a central appellate forum to reduce pendency before higher judiciary,
one of the plausible solutions to reduce such pendency would be to vest with the labour
courts and the industrial tribunals the power of review on merits. As of now, in the absence of
power of review, the decisions of labour courts and tribunals are subject to appeal before the
High Courts and the Supreme Court which results in massive backlog of cases before these
courts. The power of review therefore, will ensure that the matter under consideration is
relooked by the labour courts and tribunals and the error apparent on the face of the record is
corrected immediately before the same forum without waiting for so long before the High
Courts and the Supreme Court. Hence, the power of review will significantly help in reducing
the burden before the High Courts and the Supreme Court.

49
Bharat Bank v Employess of Bharat Bank, AIR 1950 SC 188
50
Ibid
51
L. Chandra Kumar v UOI, (1997) 3 SCC 261, para 100
52
Law Commission of India, Reform of Judicial Administration (Fourteenth Report), Vol. 1, pp. 50-51 (1968)
 CONCLUSION

The grant of power of review to the labour courts or industrial tribunals will be a stepping
stone in the industrial and labour jurisprudence of our country. The power of review on
merits is going to achieve manifold objectives. First of all, in the absence of an appellate
forum to entertain appeals from labour courts or industrial tribunals, the power to review the
decision on merits is going to significantly lower the burden on the High Courts and the
Supreme Court. The power of review will ensure that the appeals do not lie directly before
the High Court and then the Supreme Court, thereby reducing to some extent the huge
pendency which has already marred the existing judicial machinery. Such a power will ensure
that the labour courts or tribunals are able to revisit their decisions and correct errors which
are apparent on face of record. The same will also ensure that the parties do not have to wait
for long by preferring an appeal from such impugned decisions. Further, the appellate
structure of our Indian judiciary is very cumbersome and it adds more to the miseries of the
people than to provide any relief. It is therefore important to vest the labour courts or
industrial tribunals with the power to review their decision on merits.

The existing labour or industrial jurisprudence distinguishes between procedural and

substantive review (review on merits) and advocates only in favour of the former if a
proceeding is in violation of the principles of natural justice. Neither the existing statute, the
ID Act contains any provisions empowering the labour courts or tribunals with the power of
review. The recently introduced but yet to come into force, the IRs Code 2020 is also silent
on such powers. From the case laws, it is very clear that a power such as review can be
exercised by quasi-judicial authorities only if such a power if granted by way of the parent
statute. Hence, in order to embolden the labour and industrial tribunals it is very pertinent to
make amendments in the existing laws and grant them with the power to review their
decision on merits.
 BIBLIOGRAHY

Statutes

 Industrial Disputes Act, 1947

 Industrial Relations Code, 2020
 The Code of Civil Procedure, 1908

Cases

 Workmen of Dimakuchi Tea Estate v The Management of Dimakuchi Tea Estate, AIR
1958 SC 353
 Parduman Singh v State of Punjab, AIR 1958 P&H 63
 Lily Thomas v UOI, (2000) 6 SCC 224
 S. Nagaraj v. State of Karnataka, (1993) 4 SCC 595
 Food Coporation of India v SEIL Ltd., (2008) 3 SCC 440

 State of Orissa v Commr. Of Land Records and Settlement, (1998) 7 SCC 162
 Parsion Devi v Sumitri Devi, (1997) 8 SCC 715
 Ajit Kumar Rath v State of Orissa and Ors., (1999) 9 SCC 596
 Inderchand Jain v Motilal, (2009) 14 SCC 663
 Dr. (Smt) Kuntesh Gupta v Management of Hindu Kanya Maha Vidyalaya, Sitapur
(U.P.) and Ors., (1987) 4 SCC 525
 Patel Narshi Thakershi and Ors. v Pradyumansingh Arjunsingji, AIR 1970 SC 1273
 Grindlays Bank Ltd. v Central Government Industrial Tribunal and Ors., AIR 1981
SC 606
 Kapra Mazdoor Ekta Union v Management of Birla Cotton Spinning and Weaving
Mills Ltd. and Ors., (2005) 13 SCC 777
 Anil Sood v Presiding Officer, Labour Court II, (2001) 10 SCC 534
  Haryana Suraj Malting Ltd. v Phool Chand, (2018) 16 SCC 567
 Roger Mathew v South India Bank Ltd and Ors., (2020) 6 SCC 1
 Bharat Bank v Employess of Bharat Bank, AIR 1950 SC 188

 L. Chandra Kumar v UOI, (1997) 3 SCC 261

Articles

 S.G. Prashanth Murthy, ‘Power to Review Arbitral Awards- Boon or a Bane?’ (2020)
6 SCC J-27

Report

 Law Commission of India, Reform of Judicial Administration (Fourteenth Report),

Vol. 1 (1968)