Section 22(1) of the ID Act prohibits strikes by all persons employed in public utility services, including non-workmen.

The Federal Bank (Appellant), a private sector bank, challenged a Single Judge's judgment that quashed conciliation notices issued by the Regional Labour Commissioner (RLC).

The Federal Bank Officers Association (RWP/Respondent), representing officers in Scale I to III, had issued a strike notice.

The Bank triggered conciliation under Section 22 of the Industrial Disputes Act (ID Act), as banking is a notified "Public Utility Service".

The RWP filed a writ petition arguing that its members are "officers," not "workmen" under Section 2(s), and therefore the ID Act—including conciliation for industrial disputes—does not apply to them.

The Single Judge allowed the writ, holding that the absence of a "workman" status precluded the existence of an "industrial dispute".

Whether the prohibition of strikes under Section 22 of the ID Act applies to "any person" employed in a Public Utility Service, regardless of whether they qualify as a "workman" under Section 2(s).

Whether the Conciliation Officer has jurisdiction to initiate proceedings under Section 12 when a strike notice is issued by a non-workman category in a Public Utility Service.

The Court primarily applied Section 22 of the ID Act, which prohibits "any person employed in a public utility service" from striking without notice or during conciliation.

It distinguished this from Section 23, which applies specifically to a "workman".

The Court relied on Section 2(q) defining "strike" as cessation of work by a "body of persons".

and Section 2(n) regarding "Public Utility Services".

Significant precedents included *T.K. Rangarajan v. Government of Tamil Nadu*, establishing that there is no fundamental right to strike.

and *Workmen of Dimakuchi Tea Estate v. Management of Dimakuchi Tea Estate*, which clarified that "any person" in Section 22(1) is not synonymous with "workman".

The Court reasoned that Parliament deliberately used the expansive term "any person" in Section 22(1) while using "workman" in Section 23, indicating a broader embargo for Public Utility Services (PUS) to prevent economic disruption.

The Court held that banking, as a notified PUS, is vital to the national economy and public interest.

It rejected the RWP’s argument that an "industrial dispute" (involving a workman) is a prerequisite for Section 22, noting that Section 22(1) is a standalone charging provision intended to address the "menace of strikes" specifically.

The Court found that the Single Judge misinterpreted *Dimakuchi Tea Estate*; that precedent actually supports the view that "any person" in Section 22(1) includes non-workmen.

Consequently, a strike notice by officers triggers the RLC's jurisdiction to hold conciliation to maintain industrial peace, acting as a "safety valve".

The Court held that the statutory prohibition in Section 22(1) applies to all employees of a PUS, including managerial and supervisory staff.

It answered that an employer is competent to trigger conciliation proceedings the moment a strike notice is received in a PUS, irrespective of the "workman" status of the employees.

The Writ Appeal was allowed, the Single Judge's judgment was set aside, and the writ petition was dismissed.

The Court reaffirmed that the public interest in a PUS overrides the sectional interests of employees seeking to strike.

Whether the prohibition of strikes under Section 22 of the ID Act applies to "any person" employed in a Public Utility Service, regardless of whether they qualify as a "workman" under Section 2(s).

Whether the Conciliation Officer has jurisdiction to initiate proceedings under Section 12 when a strike notice is issued by a non-workman category in a Public Utility Service.

The Court primarily applied Section 22 of the ID Act, which prohibits "any person employed in a public utility service" from striking without notice or during conciliation.

It distinguished this from Section 23, which applies specifically to a "workman".

The Court relied on Section 2(q) defining "strike" as cessation of work by a "body of persons".

and Section 2(n) regarding "Public Utility Services".

Significant precedents included *T.K. Rangarajan v. Government of Tamil Nadu*, establishing that there is no fundamental right to strike.

and *Workmen of Dimakuchi Tea Estate v. Management of Dimakuchi Tea Estate*, which clarified that "any person" in Section 22(1) is not synonymous with "workman".

The Court reasoned that Parliament deliberately used the expansive term "any person" in Section 22(1) while using "workman" in Section 23, indicating a broader embargo for Public Utility Services (PUS) to prevent economic disruption.

The Court held that banking, as a notified PUS, is vital to the national economy and public interest.

It rejected the RWP’s argument that an "industrial dispute" (involving a workman) is a prerequisite for Section 22, noting that Section 22(1) is a standalone charging provision intended to address the "menace of strikes" specifically.

The Court found that the Single Judge misinterpreted *Dimakuchi Tea Estate*; that precedent actually supports the view that "any person" in Section 22(1) includes non-workmen.

Consequently, a strike notice by officers triggers the RLC's jurisdiction to hold conciliation to maintain industrial peace, acting as a "safety valve".

It answered that an employer is competent to trigger conciliation proceedings the moment a strike notice is received in a PUS, irrespective of the "workman" status of the employees.

The Writ Appeal was allowed, the Single Judge's judgment was set aside, and the writ petition was dismissed.

The Court reaffirmed that the public interest in a PUS overrides the sectional interests of employees seeking to strike.