NATIONAL LAW INSTITUTE UNIVERSITY, BHOPAL

SEMESTER VIII

PROJECT: LABOUR LAW

TITLE: Immunities Available to Trade Union in India

SUBMITTED TO: SUBMITTED BY:

Prof Mahendra Soni Adhir lot 2018 B.A.LL. B 43

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 CERTIFICATE
This is to certify that project on the topic “Immunities Available to Trade Union in India has
been prepared and submitted by ADHIR LOT, currently pursuing their B.A. LL.B. (Hons.) at
National Law Institute University, Bhopal in fulfilment of LABOUR LAW course. It is also
certified that this is their original research project and this project has not been submitted to
any other University, nor published in any journal.

Date:

Signature of student: …………………………………………

Signature of research supervisor: …………………………….

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 ACKNOWLEDGEMENT
I express my sincere gratitude to all those who helped me with this project. I am very grateful
to, Prof Mahendra Soni, who had supported us throughout this course by being an ideal
mentor. We are also thankful to the Library Administration for providing necessary books
and texts needed for the completion of this project” Finally we would like to thank our
classmates and seniors for all the guidance they had provided.

ADHIR LOT

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 Table of Contents
Introduction 5

Concept and Meaning of Trade Union 7

Purpose of Trade union 8

Trade Union Act, 1926 10

Registration of Trade union 12

Immunities of a Registered Trade Union 14

Conclusion 19

Bibliography 20

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 Introduction

Trade union is an outcome of industrialization. It is based on ‘united we stand, divided we

fall’. It is generally viewed that an organization of employees for the purpose of securing
various benefits for them is a trade union. “The traditional outlook in the labour management
relationship has changed due to industrial revolution. The relationship between employer and
employee disappeared with the introduction of modern factory system. Various social and
economic evils made it compulsory on the part of workers to devise effective means to deal
with the employers in the form of trade unions. The growth of trade union was the result of a
number of strikes, the deteriorating economic conditions of workers, low wages which could
not keep pace with soaring prices and the shortage of labour.

Hypothesis

The emergence of trade union is a boon for labourers who are unable to represent
individually. Over the period of time trade union ensured to provide a forum to facilitate
better industrial relations, industrial growth and improve productivity

Statement of Objectives

 To Study the Concept and Meaning of Trade union

 To Study the Immunities given to trade unions under the Trade union Act ,1926

Research Questions

 Whether a Trade union can be charged for the Offence of Criminal Conspiracy
 Whether agreement in restraint of trade is Void under the Trade union Act, 1926
 Whether trade union members immune have immunity against violence and Threats

Method of Study

The project is basically based on the doctrinal method of research as no field work is done on
this topic. The sources of data for this project are secondary in nature, including books, case
laws & online resources”. The mode of writing this project is descriptive & analytical

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 Statement of problem

“For ensuring the smooth functioning of union, Trade Union Act was enacted where certain
rights and liabilities protect their interests and possibility of exploitation.

Review of Literature

Ambasta Kunal- India: Trade Unions and Collective Bargaining

In this Article the Author Studies the Evolution of Trade unionism in India. Due to a surge in
industrial activity in the later part of 19th century, “the population of working class increased.
Since the employers were mainly interested only in profitability, workers were at a mercy of
the employers. Slowly, the concept of a union started taking hold in India. In 1890, mill
workers of Bombay associated under the name of Bombay Millhands Association. Although
it was not a trade union in a strict sense, it was nevertheless a start in India.
After the First World War the cost of living increased and the workers frequently agitated to
demand more pay. In the early 20th century Royal Trade Commission studied the condition
of workers and suggested the formations of Trade Unions. As per the recommendations of the
Royal Commission, Indian Trade Unions Act was passed in 1926. However, due to strong
opposition from employers, it was enforced only in 1927. The original act lacked teeth in the
sense that the formation of a Trade Union itself dependent on the recognition by the
employer. Later on several amendments were made to fix the issues. In 1947, the act was
amended widely as per the socialist inclination of the polity.

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CONCEPT AND MEANING OF TRADE UNION

Trade union is a group of employees who have grouped themselves in an organization to

secure various benefits. However, the activities of trade unions, these days are not confined to
mere securing the economic benefits. It includes welfare activities, environmental conditions
and other benefits of workers. In the present context” these are voluntary organizations
formed to protect and promote their socio-economic benefits by collective actions. In the
words of Dale Yoder, “A union is a continuing, long-term associations of employees formed
and maintained for the specific purpose of advancing and protecting the interests of members
in their working relationships.”1

S.D. Punekar, “A trade union is a monopolistic combination of wage-earners who as

individual producers are complementary to one another but who stand to employers in a
relation of dependence for the sale of their labour and production, and that the general
purpose of association is in view of that dependence to strengthen their power to bargain with
the employers or bargaining collectively.” 2 The British Trade Union Act views it as “a trade
union is a combination with the main objective of regulating the relation between workmen
and masters or between workmen and workmen or between masters and masters for imposing
of restrictive conditions on the conduct of any trade or business and also provision of benefits
to members.” Indian Trade Unions Act, 1926 defines trade unions as “any combination,
whether temporary or permanent, formed primarily for the purpose of regulating the relations
between workmen and employers or between workmen and workmen, or between employers
and employers, or for imposing restrictive conditions on the conduct of any trade or business,
and includes any federation of two or more trade unions.3 ”

This definition includes associations of employees. Ordinarily, a trade union is referred to a

group of workers. Therefore, it may be defined as a continuous association of wage-earners to
maintain the conditions of their working lives and ensure a better and healthier status in
society as well as in industry.

“The following features have been highlighted in the above noted trade unions

1
Dale Yoder, “Personnel Management and Industrial Relations” (1974)
2
Punekar, S.D. “Trade Unionism in India” (1948) p
3
Sec. 2(h) of The Trade Unions Act, 1926.

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  It always acts through united actions of members, i.e., collectively.

 It is voluntary organization of workers.

 It protects the economic interests and makes efforts to the welfare of its workers. It is

found for the pursuit of common interests of its workers.

 It is concerned with economic, political, social and cultural life of its members.

 It includes federations of trade unions also.

 Its role is similar to that of mediators within an organization. Though, it is primarily

meant for protection of interests of its members but it also plays the role of

intermediary between labour and management.

PURPOSES OF TRADE UNIONS

Trade unionism is an organized expression of aspirations, attitudes, wishes and needs of the
working class. It functions collectively to protect and promote the socio-economic interests of
its members. Its function is not only to press for improvement in living standards but also to
involve in various wider issues which directly or indirectly affect the living rate of its
members. It is a reaction to the bourgeois class to bring true freedom of the working class.
The trade union generally pursues the following broad objectives:

 Steady and Secure Employment

The employer at his own may not be able to guarantee to the workers regarding steady and
secured employment. His capability to provide guarantee to the employees is limited and it
depends on the state of the market which is beyond his control. The workers are involved in
political action to achieve the aspiration of security of employment. As and when there is
threat of elimination form the organizers in the form of discharge, dismissal, compulsory
retirement, retrenchment etc” trade unions strongly resist it.

 Rationalisation

The economic security of workers also depends upon the management’s personal policies like
retirement, promotion, transfer, assignment of different nature of jobs to the employees, “the
disciplining of employees and lay-off. If all these policies are not governed by rational
policies and statutory rules, there will be greater danger to equal and natural justice.

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  Fostering Equity and Industrial Democracy:

The attempt of the trade union is to promote democratic values through holding elections
periodically and to choose their leaders. This empowers the grass root workers to participate
in the process of making any decision in the organization indirectly. It also enables a lowest
cadre employee to become an office bearer and participate in collective bargaining. It aims at
achieving industrial democracy, equity and peace.

 Legislative enactments

The attempt of the trade union remains to get legal sanctions of their demands in the form of
Acts to make it a permanent feature of the contract between the labour and management. To
achieve this purpose, the trade union takes recourse of political actions either through
forming their own political party or through support of any other political party.

 Physical Security

The trade union asks or pressurizes the employer to provide the employees suitable physical
work environment and to preserve the health and safety of the workers on their adherence to
safety provisions and policies.

 Social Security

The endeavour of a trade union is also to provide a peaceful retired life to its employees so it
also tries to provide adequate benefits of retirement. To achieve this target, the union
pressurizes the employers to contribute for regular and adequate statutory funds which are
meant to protect the future well-being of its employees.” The organizational-level schemes
may also be made for improving the retirement benefits to the employees.

 Negotiation Machinery

Every effort of a trade union is to improve the labour-management relationship through

constant negotiation with the management. “To improve the superior-subordinate relationship
by resolving the grievances of workers, the trade union works systematically and through
appropriate means. Therefore, the trade union provides emotional security to its members by
ensuring peace and harmony at the workplace.4

TRADE UNIONS ACT, 1926

4
Davar, R.S., “Personnel Management and Industrial Relations” (2003)

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The main object of the Trade Unions Act, 1926 is to provide machinery for the registration,
regulation and protection of the rights and privileges of the trade unions. The term ‘trade
union’ used in this act is not confined alone to the workers’ union, but also includes
employers’ association as well. The act also prescribes for what purposes the trade union may
spend its general funds and also give provisions for creating a separate fund for political
purposes. The main object of the act is to ensure industrial harmony. The members of the
registered trade unions are protected from various civil and criminal liabilities and enjoy
immunities and privileges.

The Trade Unions Act, 1926 has 5 chapters and 33 sections.

 Chapter I contains Sections 1 and 2. Section 1 gives primary aspects viz. title, extent

and application of the act. Section 2 defines various terms under this act viz. Trade

Union, Workmen, Trade, Business etc.

 Chapter II contains Section 3 to 14 and gives provisions for the registration of trade

unions.

 Chapter III contains Section 15 to 28” dealing with rights and liabilities of the

registered trade unions.

 Chapter IV contains Sections 29 and 30, conferring power on the appropriate

government to make regulations regarding the trade unions. By exercising the power

conferred under Section 29 of the act, the Union Government of India enacted “The

Trade Unions Regulations, 1938”, and the state governments were also empowered to

enact regulations for trade unions of the respective states.

 The Chapter V of the act contains Sections 31 to 33 gives provisions for the penalties

and procedure.

What is a Trade Union? Meaning & Definition

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A Trade Union is commonly understood as an association of wage earners or workers.
Usually, “it is a voluntary association of workers in a particular industry or craft. Trade
Union is an association of wage earners for the purpose of maintaining and improving their
working conditions. The definition of ‘Trade Union’ according to the Trade Unions Act,
1926 is same as the definitions in the British Trade Union Acts of 1871, 1875 and 1913.

Section 2(h) of the Trade Unions Act, 1926 defines Trade Union 5 as “any combination
whether temporary or permanent, formed primarily:

 for the purpose of regulating relation between:

I. Workmen and employers; or
II. Workmen and workmen; or
III. Employers and employees.
 imposing respective conditions on the conduct of any trade or business and
includes any federation of two or more trade unions, is called Trade Union:
Provided that this act shall not affect-
I. Any agreement between partners as to their own business.
II. Any agreement between an entrepreneur and those employed by him as to
such employment; or
III. Any agreement in consideration of the sales of the goodwill of a business or of
instruction in any profession” trade or handicraft.

Important elements of Trade Union:

 There must be combination of workmen and employers;

 There must be trade or business “and
 The main object of the Union must be to regulate relations of employers and
employees or to impose restrictive conditions on the conduct of any trade or business.

Registration of Trade Union

The main object of the Trade Unions Act, 1926 is to provide machinery for registration and
regulation of Trade Unions. Although registration of a trade union is not mandatory, it is
5
Trade Unions Act, 1926 along with Central Trade Unions Regulations, 1938. – Universal Law Publishing

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advisable to register the trade unions as the registered trade unions are entitled to get several
benefits, immunities and protection under the act. There are specific rights and privileges
conferred on the members of the registered trade unions. The members of the registered trade
unions are entitled to get protection, immunity and certain exceptions from some civil and
criminal liabilities. A trade union can only be registered under the Trade Unions Act, 1926,
and cannot be registered under any other act including the Societies Registration Act or the
Co-operative Societies Act or the Indian Companies Act.

A Civil Servants’ Union cannot be registered under the Trade Unions Act, 1926. In the case
of Tamilnadu N. G. O’s Union vs. The Registrar of Trade Unions (AIR 1962, Mad. 2341) 6
the Madras High Court dismissed the appeal on the ground that, to get the trade union
registered under the Trade Unions Act, 1926, the members of the union must be workmen
engaged in trade, business or industry and the appellants in this case are not in that capacity”
as they are civil servants engaged in the tasks of the sovereign government.

In the case of Registrar of Trade Unions, West Bengal vs. Mihir Kumar Gocho (AIR 1963,
Cal. 56)7, the Calcutta High Court held that employees of E.S.I. Corporation would come
within the meaning of workmen and hence, they could be registered under the Trade Unions
Act.

Chapter II containing Sections 3 to 14 of the Trade Unions Act, 1926 and Central Trade
Union Regulations, 19388containing 17 Rules and Forms A, B and C “provide for the
procedure and formalities for registration of the trade unions. For registration of the trade
union, an application shall be submitted to the Registrar of Trade Unions appointed by the
appropriate government under Section 3 of the Trade Unions Act, 1926. Section 4 provides
for the mode of registration.

According to Section 13 of the act, every registered trade union shall be a body corporate by
the name under which it is registered. Such registered trade unions will have perpetual
succession and a common seal. A registered trade union can sue in its own name and can
acquire movable and immovable properties in its own name.

6
Tamilnadu N.G. O’s Union vs. The Registrar of Trade Unions (AIR 1962, Mad. 2341)
7
Registrar of Trade Unions, West Bengal vs. Mihir Kumar Gocho (AIR 1963, Cal. 56)
8
Trade Unions Act, 1926 along with Central Trade Unions Regulations, 1938. – Universal Law Publishing

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Registration (Sec.8)- The Registrar, on being satisfied that the Trade Union has complied
with all the requirements of this Act in regard to registration, shall register the Trade Union
by entering in a register, to be maintained in such form as may be prescribed the particulars
relating to the Trade Union contained in the statement accompanying the application” for
registration.9

Privileges / Immunities of a Registered Trade Union

In the case of “Buckingham and Carnatic Mills,” the employers were awarded damages and
the unions were held responsible for illegal conspiracies. The “Trade Unions Act, 1926” has
made provisions for the members and office-bearers of a registered trade union from criminal
and civil conspiracies during the strikes and causing any financial loss to the employer. “The
Trade Unions Act, 1926” seeks to insulate two types of protection only to a fraction of labour
force, i.e., exemption from criminal conspiracy and exemption from civil suits under section
17 & 18.

1. Exemption from Criminal Conspiracy (Sec. 17)

9
Section 8 of the Trade Unions Act, 1926.

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Under section 17 of the Act, the registered trade unions are exempted from prosecution for
criminal conspiracy subject to certain circumstances. “Any agreement to do any illegal act
itself is a criminal offence under the existing criminal law. For example, if two or more
persons persuade workmen to breach the agreement with the employers will be guilty of
criminal conspiracy. But section 17 of the Act protects the Unionists from criminal
conspiracy under such circumstances. It says that “No office-bearer or member of a registered
trade union shall be liable for punishment under sub-section (2) of Section 120 B of the
Indian Penal Code in respect of any agreement made between the members for the purpose of
furthering any such object of the trade union as is specified in Section 15, unless the
agreement is an agreement to commit an offence.10 The immunity is, however, available only:

(i) to office-bearers and members of registered trade unions;

(ii) for agreement between the members;

(iii) such agreement that may further any such trade union object as is specified in
Section 15 of the Act; and
(iv) such agreements are not to commit an offence.”

Section 17 & 18 of the Indian Trade Unions Act grant certain exemptions to members of a
Trade Union, “but there is no exemption against either an agreement to commit an offence
or intimidation, molestation or violence, where they amount to an offence. Members of a
trade union may resort to peaceful strike, that is to say, cessation of work with the
common object of enforcing their claims. Such strikes must be peaceful and not violent
and there is no exemption when an offence is committed. Therefore, a concerted
movement by workmen by gathering together either outside the industrial establishment or
inside, within the working hours is permissible when it is peaceful and does not violate the
provisions of law. But when such a gathering is unlawful or commits an offence then the
exemption is lost.11
Where it resorts to confinement of persons, criminal trespass or where it becomes violent
and indulges in criminal force or criminal assault or mischief to person or property or
molestation or intimidation, the exemption can no longer be claimed. The offence under
section 7 of the Criminal Law (Amendment) Act, 1932 which prohibits obstructing and
use of violence or intimidation and loitering and persistently following and other acts
10
Section 17 of the TU Act, 1926.
11
C.B. Mamoria & others, “Dynamics of Industrial Relations” (2014)

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 mentioned therein, if done with intent to cause any person to abstain from doing or to do
any act which such person has a right to door abstain from doing” is an offence
mentioned in Section 17 of the Act. There is no immunity if the act falls within the scope
of above section of the Act of 1932.
Nature of Exemption “Section 17 of the Act which grants exemptions from conspiracies,
raises an issue with regard to the very nature of the exemption. Section 120-A of IPC
defines Criminal Conspiracy,
(i) an agreement between two or more persons to commit an offence, i.e., in, general, an
act which is punishable under IPC or any other law for the time being in force; and
(ii)an overt act done in pursuance of an agreement between two or more persons to do an
illegal act or to do a legal act by “illegal means. 12 “The word 'illegal' under IPC includes,
“inter alia: everything which is prohibited by law, or which furnishes ground for a civil
action.” The breach of contract and damage to the property of employer cease to be
actionable under section 17 of the Act. Hence, do not amount to criminal conspiracy as
defined in IPC, section 120-A read with section 43. Here the question arises as to what is
the criminal liability. “In considering the matter, it is relevant to note that Section 17 does
not grant charter of liberty to commit an offence, which is punishable with death, life
imprisonment or rigorous imprisonment for a term of two years or more”. In the Trade
Unions Act, 1926, the last words of the Section 17 point out that “it does not insulate
agreement to commit any offence whatsoever. Perhaps the immunity is confined to an
agreement between two or more persons to do, or cause to be done, acts which are
prohibited by law but which neither amount to an offence nor furnish grounds for civil
action.
In Jay Engineering,13the Court while interpreting the provisions of Section 17 observed:
“No protection is available to members of a trade union for any agreement to commit an
offence ... When a group of workers, large or small, combine to do an act for the purpose of
one common aim or object, it must be held that there is an agreement among the workers to
do the act and if the act committed is an offence, it must similarly be held that there is an
agreement to commit an offence.”
2. Exemption from Civil Suits (Sec. 18)

12
Section 120-A of“Indian Penal Code, 1860
13
Jay Engineering Works Ltd. v. Staff,”AIR 1968 Cal. 407.

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 Exemption is granted under section 18 of the Trade Unions Act, 1926 to register trade unions
from civil suits. “No suit or other legal proceeding shall be maintainable in any Civil Court
against any registered Trade Union or any office-bearer or member thereof in respect of any
act done in contemplation or furtherance of a trade dispute to which a member of the Trade
Union is a party on the ground only that such act induces some other person to break a
contract of employment, or that it is in interference with the trade” business or employment
of some other person or with the right of some other person to dispose of his capital or of his
labour as he wills.14
3. Exemption from Tortious Liability (Sec. 18 (2))
“A registered Trade Union shall not be liable in any suit or other legal proceeding in any civil
court in respect of any tortuous act done in contemplation or furtherance of a trade dispute
by an agent of the Trade Union if it is proved that such person acted without the
knowledge of, or contrary to express instructions given by, the executive of the Trade
Unions.15 ” “The above section does not afford immunity to the members or office-bearers
of a trade union for an act of deliberate trespass. The immunity also cannot be availed by
them for unlawful or tortuous act. Further, such immunity is denied if they indulge in an
illegal strike or gherao. Moreover, the immunities enjoyed by the union do not impose any
public duty on the part of the union.16
“However, the section raises several problems.17
 like immunity from criminal conspiracy, immunity from civil action is also confined

to members of the registered trade unions. We have already seen that such protection

was limited to 10.6 per cent of the labour force in 2005.

 it does not afford adequate protection from civil liabilities. For, it is arguable whether

it gives protection and, if so, to what extent in excess of the aforementioned Section

17 of the Trade Unions Act. A suit or proceeding may not be maintainable for a

number of reasons. Does it necessarily follow that the conduct does not' furnish

ground for civil action' within the meaning of Section 43 of the Indian Penal Code?

14
Section 18 (1)“of the Trade Unions Act, 1926.
15
Section 18 (2) of the Trade Unions Act, 1926.
16
“Chemosyn Pvt. Ltd v. Kerala Medical and Representatives Association”
17
Anandjee, “Impact of Labour Laws on Trade Union Movement,”

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  the expression 'in contemplation or furtherance of a trade dispute to which a member

of the trade union is a party' is obviously narrower than the ambit of protection under

the said Section 17.

 Section 18 helped in maintenance of union funds, howsoever meagre. The real

significance is in rejecting the application of the common law doctrines of restraint of

trade and criminal conspiracy in so far as they encroach on the field of labour

management relations. Together with Section 17, it provides a great impetus for, and

facilitates the active participation of 'outside leaders' in the trade union movement.”

Some workers went on illegal and unjustified strike in Rohtas Industries. 18 The matter was
referred to the arbitration as the question had arisen whether the employers had any right of
civil suit for the loss against the workers. The arbitrator held that “the workers, who
participated in an illegal and unjustified strike, were jointly and severally liable to pay
damages.” The Patna High Court quashed the order of arbitrator and held that “employers
had no right of civil action for damages against the employees participating in an illegal
strike within the meaning of Section 24 of the Industrial Disputes Act, 1947.” The Supreme
Court affirmed the decision of the High Court. “Therefore, it is evident that section 18 of the
Act, grants civil exemption to members in respect of strikes by the trade unions
In the case of Reserve Bank of India 19the Calcutta High Court once again held that “in order
to secure immunity from civil liability under Section 18, inducement or procurement in
breach of employment in furtherance of trade dispute must be by lawful means and not by
means which would be illegal or wrong under any other provisions of the law.”

4. Enforcement of Agreements (Sec. 19)

Notwithstanding anything contained in any other law for the time being in force, an
agreement between the members of a registered Trade Union shall not be void or voidable
merely by reason of the fact that any of the objects of the agreement are in restraint of trade: 20
18
AIR 1963 Patna 170
19
“Reserve Bank of India v. Ashis, 73 CWN 388, (1969).”
20
Section 19 of the Trade Unions Act, 1926.

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” “However, the provision under section 19 shall not enable any civil court to entertain any
legal proceedings instituted for the express purpose of enforcing or recovering damages for
the breach of any agreement concerning the conditions on which any member of trade union
shall or shall not

(i) sell their goods

(ii) transact business

(iii) work

(iv) employ; or be employed. Although, the Act does not provide for enforceability of an
agreement between the management and workers trade union. The net effect of the section is
to validate agreement which is invalid being in restraint of trade under Section 27” read with
Sections 23 and 24 of the Contract Act, 1872.21

Conclusion

The emergence of trade union is a boon for labourers who are unable to represent
individually. Trade union form with the object of taking collective action for their benefits
and to obtain their rights. “For ensuring the smooth functioning of union, Trade Union Act
was enacted where certain rights and liabilities protect their interests and possibility of
exploitation. The Trade Unions Act, 1926 provides for registration of trade unions with a
view to form lawful organisation of labour to enable collective bargaining. At the same time,
it can’t be absolutely denied that it has posed some difficulties in the smooth functioning of
an industry in the following way. Too many unions cause intra-union and inter-union rivalry
and thus loss of precious resources that can be used for worker's welfare. Due to
politicization of unions causes the union to overlook the true welfare and benefits of the
worker. Outside Leadership causes unions to lose focus because such leadership does not
understand the problems of the labourers. Closed Shop/Union Shop companies forces
labourers to join the union and thus causes monopoly. Close shops/Union Shops are now
illegal in many countries. Sometime the employers do not recognize unions. Despite this
issue most trade unions have managed to foster an environment so as to enable a healthy
discussion between the workers and employers with respect to any demands the workers may
have. Furthermore, trade unions in India have, over the period of time” ensured to provide a
forum to facilitate better industrial relations, industrial growth and improve productivity.

21
Tulsidas Paul v. Second Labour Court, AIR 1963

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 Bibliography

 Sinha: Industrial Relations, Trade Unions, and Labour Legislation,

 S.C. Srivastava: Industrial Relations and Labour Laws.

 Bare Act: Trade Unions Act, 1926 along with Central Trade Unions Regulations,

1938.

 P.L. Malik: K.D. Srivastava’s Law Relating to Trade Unions and Unfair Labour

Practices in India: with Supplement.

 B.L. Mehta: Trade union movement in India

 Goswami V.G., Labour & Industrial Laws,

 Misra S.N., Labour & Industrial Laws,

 Puri S.K., Labour & Industrial Law,

INTERNET SOURCES

 https://blog.ipleaders.in/what-every-indian-needs-to-know-about-trade-union-related-

laws-in-india

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 https://www.legalserviceindia.com/legal/article-7074-civil-and-criminal-immunities-

of-registered-trade-unions.html

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