Acts and Sections Discussed:

1. Maharashtra Recognition of Trade Unions and Prevention of Unfair Labour Practices (MRTU & PULP) Act, 1971 - Section 32 (Deciding matters related to labor complaints)
2. Industrial Disputes Act, 1947 - Employer-employee relationship issues
3. Contract Labour (Regulation and Abolition) Act, 1970 - Contracts in labor arrangements
4. Article 227 of the Constitution of India - Jurisdiction of High Courts

Para-wise Main Facts:

1. Jurisdictional Challenge of Industrial Court: The central issue revolved around whether the Industrial Court had jurisdiction to entertain complaints of unfair labor practices under the MRTU & PULP Act when the employer-employee relationship was disputed, particularly in cases where the declaration of a contract as sham and bogus was sought.

2. Reliance on Key Judgments: The petitioner, Tata Steel Ltd., contested the Industrial Court’s jurisdiction based on judgments like General Labour Union (Red Flag) vs. Calico Printing Co. and Cipla Ltd., where the courts held that establishing an employer-employee relationship is essential before considering complaints under the MRTU & PULP Act.

3. Judgment in Hindalco Case: The petitioner referenced Hindalco Industries Ltd., where the court ruled that the Industrial Court could not rule on unfair labor practice complaints unless the employer-employee relationship was indisputable.

4. Precedents on Jurisdiction Limits: The court discussed previous rulings, including Vividh Kamgar Sabha, affirming that only when the employment status is confirmed can unfair labor practice complaints be pursued under the MRTU & PULP Act. If the relationship is contested, the dispute must first be settled under the Industrial Disputes Act.

5. Evidence and Documentation: In the present case, Tata Steel Ltd. argued that the respondent union failed to provide documents proving a direct employer-employee relationship, challenging the basis of the Industrial Court’s ruling.

6. Industrial Court's Error: The High Court noted that the Industrial Court had erred by assuming jurisdiction without sufficient evidence of a subsisting employer-employee relationship prior to 2018, highlighting that the mere denial by Tata Steel and lack of documentary evidence could not form the basis for jurisdiction.

7. Outcome: The High Court allowed the writ petition, quashing the Industrial Court's order. It ruled that the complaint could not proceed under the MRTU & PULP Act unless the employer-employee relationship was first established via the appropriate forum.

Ratio Decidendi (Reasoning): The Industrial Court lacks jurisdiction to entertain complaints of unfair labor practice when the employer-employee relationship is disputed. This dispute must first be resolved under the Industrial Disputes Act. Without clear documentation of the relationship, the jurisdiction cannot be assumed.

The ruling clarifies that before approaching the Industrial Court for unfair labor practices under the MRTU & PULP Act, the existence of a direct employer-employee relationship must be indisputable. In cases where the employment status is contested, the dispute should be first addressed under the Industrial Disputes Act.

Subjects:

Jurisdiction, Unfair Labor Practices, Contract Labor, MRTU & PULP Act, Employer-Employee Relationship.

Labor law, Jurisdiction, MRTU & PULP, Industrial Court, Tata Steel, Employer-Employee Dispute, Contract Labor, High Court Judgment.