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"Mere illegality of the strike does not per se spell unjustifiability". J. Krishna Iyer In which case declared so

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For Labour Law, focus on landmark judgments and the key principles or quotes laid down by prominent judges like Justice V.R. Krishna Iyer. Understanding the distinction between legal/illegal and justified/unjustified strikes is a fundamental concept often tested.
Updated On: Jul 13, 2026
  • Chandramalai Estate v. Its workmen
  • Associated Cement Ltd., v. Their workmen
  • Gujarat Steel Tubes v. Gujarat Steel Tubes Mazdoor Sabha
  • Indian General Navigation of Railway Co. Ltd., v.Their workmen
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The Correct Option is C

Approach Solution - 1

Industrial law treats legality and justifiability of a strike as two separate questions. Legality asks whether the workmen followed the notice and procedure rules in the Industrial Disputes Act, 1947. Justifiability asks whether the workmen had a fair reason to strike, such as unfair treatment by the employer. A strike can fail the first test and still pass the second. Keeping that test in mind while checking each case name given here settles the question.

  1. Chandramalai Estate v. Its Workmen: deals with plantation workers and lays down early tests for justification of a strike, but it is not where this exact phrase appears.
  2. Associated Cement Ltd. v. Their Workmen: concerns wage and service disputes at cement companies, unconnected with this legality-justifiability formula.
  3. Gujarat Steel Tubes v. Gujarat Steel Tubes Mazdoor Sabha: here Krishna Iyer J. holds that an illegal strike is not automatically unjustified, since the workmen's grievance and the employer's conduct still have to be weighed separately. This is the exact source of the quoted line.
  4. Indian General Navigation and Railway Co. Ltd. v. Their Workmen: discusses strikes in the context of misconduct, not this legality-justifiability separation.

Because only the Gujarat Steel Tubes ruling builds this two-test framework and carries Krishna Iyer J.'s language, that is the case being asked about.

The correct answer is Gujarat Steel Tubes v. Gujarat Steel Tubes Mazdoor Sabha.

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Approach Solution -2

Another way into this question is to work backward from the judge named, Justice V.R. Krishna Iyer, rather than from the strike-law principle itself. Krishna Iyer J. was known for his vivid, aphoristic style of writing judgments, and this phrase is one of his well known lines on labour law. Checking which of the four cases actually carries a judgment written in that voice narrows the field quickly.

  1. Chandramalai Estate v. Its Workmen: an older ruling from a different bench, decided before Krishna Iyer J.'s tenure on the labour law bench reached its most active phase, so it does not carry this line.
  2. Associated Cement Ltd. v. Their Workmen: not authored around this theme, and its subject matter of wage and bonus claims gives no occasion for a remark on strike legality versus justifiability.
  3. Gujarat Steel Tubes v. Gujarat Steel Tubes Mazdoor Sabha: a 1980 judgment written by Krishna Iyer J., where he takes up the question of strikes at length and states in clear terms that illegality alone does not make a strike unjustified. The reasoning and the phrasing both match the question.
  4. Indian General Navigation and Railway Co. Ltd. v. Their Workmen: an older labour dispute decided on different facts, not carrying this observation.

Working from the judge's identity and known style points to the same case as working from the doctrine: the ruling on strikes handed down in the Gujarat Steel Tubes dispute.

The correct answer is Gujarat Steel Tubes v. Gujarat Steel Tubes Mazdoor Sabha.

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