On 28 August 1985, a two-judge bench of the Supreme Court read Section 2(oo) of the Industrial Disputes Act with the breadth its language demands — every termination by the employer is retrenchment unless it falls within one of the enumerated exceptions.
On 6 March 1973, a two-judge bench of the Supreme Court gave Section 11A its foundational construction — the Industrial Tribunal's own satisfaction on guilt and punishment displaces the four-grounds restraint of Indian Iron & Steel, and the Tribunal may alter the punishment imposed by an employer.