A) ABSTRACT / HEADNOTE
This landmark judgment in The Newspapers Ltd. v. The State Industrial Tribunal, U.P., (1957) dealt with the nature of “industrial disputes” under the U.P. Industrial Disputes Act, 1947 and the central Industrial Disputes Act, 1947. The Supreme Court of India ruled that a dispute between an employer and a single workman does not qualify as an “industrial dispute” unless supported or espoused by a body of workmen or a representative trade union. The Court found that Tajammul Hussain, a dismissed lino typist, lacked such representative support, and hence the State’s reference to the Industrial Tribunal was void. The judgment analyzed prior conflicting interpretations and drew a clear line on the concept of collectivism in industrial jurisprudence. This decision overruled previous positions such as in Swadeshi Cotton Mills Co. Ltd. v. Their Workmen, (1953) 1 LLJ 757, where it was held that an individual workman’s dispute could constitute an industrial dispute. The judgment reasserted the collectivist purpose behind labour dispute resolution and emphasized the constitutional limits of administrative power in industrial adjudication.

Keywords: Industrial Dispute, U.P. Industrial Disputes Act, Single Workman, Trade Union, Tribunal Jurisdiction

B) CASE DETAILS

i) Judgement Cause Title:
The Newspapers Ltd. v. The State Industrial Tribunal, U.P.

ii) Case Number:
Civil Appeal No. 213 of 1956

iii) Judgement Date:
March 20, 1957

iv) Court:
Supreme Court of India

v) Quorum:
Justice B.P. Sinha, Justice J.L. Kapur, and Justice N.H. Bhagwati

vi) Author:
Justice J.L. Kapur

vii) Citation:
AIR 1957 SC 532; (1957) SCR 752

viii) Legal Provisions Involved:

• Section 2(k), Industrial Disputes Act, 1947

• Section 2, U.P. Industrial Disputes Act, 1947

• Section 3, U.P. Industrial Disputes Act, 1947

• Article 226 and Article 133(1)(c), Constitution of India

ix) Judgments Overruled by the Case (if any):
Swadeshi Cotton Mills Co. Ltd. v. Their Workmen, (1953) 1 LLJ 757 – disapproved on specific point

x) Case is Related to Which Law Subjects:
Labour and Industrial Law, Constitutional Law, Administrative Law

C) INTRODUCTION AND BACKGROUND OF JUDGEMENT
The dispute arose when Tajammul Hussain, employed as a lino typist by The Newspapers Ltd., was dismissed for incompetence. His termination was not contested by his fellow employees or any trade union connected to the appellant. However, the U.P. Working Journalists Union, which had no link with the appellant’s workforce, referred the matter to the Conciliation Board and subsequently to the State Government. The Government made a reference to the Industrial Tribunal under Section 3 of the U.P. Industrial Disputes Act, 1947, and the Tribunal ruled in favour of reinstatement. The appellant challenged the jurisdiction of the Tribunal, contending the absence of an “industrial dispute” as per Section 2(k) of the Industrial Disputes Act, 1947. The case thus revolved around the legal validity of referring a purely individual dispute to adjudication without collective backing from fellow workers or trade unions connected to the employer.

D) FACTS OF THE CASE
Tajammul Hussain served as a lino typist at The Newspapers Ltd. He was dismissed from service on May 8, 1952, under clause 12(ii) of the Standing Orders due to alleged incompetence. No worker at the company protested the dismissal. Furthermore, no workers’ union within the appellant company or any allied trade unions supported Hussain. Surprisingly, the U.P. Working Journalists Union from Lucknow, with whom Hussain had no affiliation, took up the issue. The union approached the Conciliation Board in Allahabad. The matter was then referred to the Industrial Tribunal by the State Government under a notification dated June 3, 1953, which framed an issue regarding the legality of Hussain’s termination. The Tribunal ruled in favour of Hussain, ordering reinstatement with full back wages. This award was upheld by the Labour Appellate Tribunal. The appellant challenged the jurisdiction through a writ petition under Article 226, which was dismissed by the High Court. A special appeal was also dismissed. The Supreme Court granted leave under Article 133(1)(c), raising key constitutional and statutory questions about the scope of “industrial dispute.”

E) LEGAL ISSUES RAISED

i) Whether a dispute between an employer and a single workman without support from other workmen or a trade union constitutes an “industrial dispute” under the U.P. Industrial Disputes Act, 1947 and the Industrial Disputes Act, 1947.

F) PETITIONER/APPELLANT’S ARGUMENTS

i) The counsels for Petitioner / Appellant submitted that
The counsel submitted that the dispute lacked the essential feature of collectivism. They argued that Section 2(k) of the Industrial Disputes Act, 1947 and Section 2 of the U.P. Industrial Disputes Act both define “industrial dispute” as involving multiple workmen or a representative union, not an isolated individual grievance. They also contended that the U.P. Working Journalists Union, not being a union of the appellant’s employees, had no locus standi to raise the dispute. The petitioner emphasized the legislative intent to prevent collective unrest and not to convert every individual termination into a statutory industrial dispute. They relied on precedents like D.N. Banerji v. P.R. Mukherjee, (1953) SCR 302 and Central Provinces Transport Services Ltd. v. Raghunath Gopal Patwardhan, (1956) SCR 956, which held that an individual dispute becomes industrial only when supported by fellow employees or a union.

G) RESPONDENT’S ARGUMENTS

i) The counsels for Respondent submitted that
The respondents argued that the definition of “industrial dispute” was broad enough to cover an individual workman’s grievance. They relied on the decision in Swadeshi Cotton Mills Co. Ltd. v. Their Workmen, (1953) 1 LLJ 757, which recognized the right of an individual to raise a dispute. They also asserted that the Government’s power to refer disputes under Section 3 of the U.P. Act was not limited by numerical strength of the claimants. They submitted that even if the Working Journalists Union was not directly related, its concern and intervention provided legitimacy to the dispute. The respondent supported the administrative nature of the reference and contended that the Tribunal’s jurisdiction could not be challenged post facto on technicalities.

H) RELATED LEGAL PROVISIONS

i) Section 2(k), Industrial Disputes Act, 1947:
Defines industrial dispute as one between employers and employers, employers and workmen, or workmen and workmen involving employment-related matters. [Link: https://indiankanoon.org/doc/1517022/]

ii) Section 3, U.P. Industrial Disputes Act, 1947:
Empowers State Government to make special provisions for maintaining employment, including referring disputes to industrial tribunals.

iii) Article 226, Constitution of India:
Empowers High Courts to issue writs for enforcement of legal rights. [Link: https://indiankanoon.org/doc/1741325/]

iv) Article 133(1)(c), Constitution of India:
Provides for appeals to the Supreme Court on substantial questions of law of general importance. [Link: https://indiankanoon.org/doc/1111515/]

I) JUDGEMENT

a. RATIO DECIDENDI
The Court held that an individual dispute does not constitute an “industrial dispute” under the U.P. or Central Acts unless it is espoused by a body of workmen or a recognized trade union of the same employer. The Working Journalists Union lacked such representative capacity. The Court interpreted the statutes as aiming to resolve collective disputes that affect industrial harmony and public order, not personal employment grievances.

b. OBITER DICTA 
The Court remarked that an award of an Industrial Tribunal has far-reaching consequences and binds not just the disputing parties but future entrants as well. This supports the necessity for collective representation in any reference.

c. GUIDELINES 

• A dispute by a single workman must be supported by fellow workmen or a trade union to become an industrial dispute.

• Administrative references under industrial law are not immune to judicial scrutiny.

• Trade unions not connected with the employer’s workforce cannot create jurisdiction where none exists.

• Interpretation of statutes must consider the object of the law – industrial peace through collective redress.

J) CONCLUSION & COMMENTS
The Supreme Court’s ruling in this case reinstates the primacy of collectivism in industrial law. It preserves the legislative intent of the Industrial Disputes Act, emphasizing industrial harmony, and clarifies that a purely individual employment grievance cannot override the procedural safeguards and statutory mandates. The case thus serves as a vital precedent in preventing arbitrary extensions of State power in referring matters to tribunals without proper jurisdictional basis.

K) REFERENCES

a. Important Cases Referred

i. Central Provinces Transport Services Ltd. v. Raghunath Gopal Patwardhan, (1956) SCR 956
ii. D.N. Banerji v. P.R. Mukherjee, (1953) SCR 302
iii. Swadeshi Cotton Mills Co. Ltd. v. Their Workmen, (1953) 1 LLJ 757
iv. State of Madras v. C.P. Sarathy, (1953) SCR 334
v. Kandan Textile Ltd. v. Industrial Tribunal, Madras, AIR 1951 Mad 616
vi. J. Chowdhury v. M.C. Bannerjee, 1951 55 CWN 256
vii. United Commercial Bank Ltd. v. Commissioner of Labour, ILR 1952 Madras 43
viii. George Hudson Ltd. v. Australian Timber Workers Union, (1923) 32 CLR 413
ix. Metal Trades Employers Assn. v. Amalgamated Engineering Union, (1935) 54 CLR 387

b. Important Statutes Referred
i. Industrial Disputes Act, 1947, Section 2(k), 33, 18
ii. U.P. Industrial Disputes Act, 1947, Section 2, 3, 8
iii. Constitution of India, Article 226, 133(1)(c)
iv. General Clauses Act, 1897, Section 13
v. Indian Trade Unions Act, 1926