On 1 May 2001, a five-judge Constitution Bench of the Supreme Court affirmed the Shambhu Nath Goyal threshold-pleading rule — management must, at the first opportunity in its written statement before the Tribunal, reserve the right to lead fresh evidence in the event the domestic enquiry is found invalid.
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.