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2025 DIGILAW 1883 (TS)

BHEL Workers Union, Affiliated to AITUC, Rep. by its President SDV Krishnam Raju v. State of Telangana Rep. by its Principal Secretary, Labour Department

2025-12-19

NAGESH BHEEMAPAKA

body2025
ORDER : Nagesh Bheemapaka, J. Petitioner - BHEL Workers Union is affiliated to the All India Trade Union Congress (AITUC), a recognized central trade union organization. It is stated, the said Union participated in the Trade Union verification elections conducted by the Deputy Chief Labour Commissioner (Central), Hyderabad on 12.08 2023, along with other trade unions operating in the establishment. Upon conclusion of the said verification process, the BHEL Workers Union (AITUC) secured the highest number of votes and was accordingly, declared as the Majority Union. Consequently, the Management of Bharat Heavy Electricals Limited acknowledged the status of Petitioner Union as the recognised union and addressed a letter to Petitioner congratulating him in his capacity as the President of the Union, thereby acknowledging both the outcome of the verification elections and the leadership of Petitioner. 1.1. Petitioner further states that after the declaration of the Union as the Majority Union, it became necessary, in accordance with established trade union practice, to elect new office bearers to administer the affairs of the Union for the ensuing period. In this regard, steps were initiated to convene the Annual General Body Meeting of the Union. The AITUC State President was requested to act as the Election Officer, and he accordingly, agreed to preside over the General Body Meeting and conduct the election process in a fair and transparent manner. The Annual General Body Meeting was thus convened and held on 11.07.2024 under the supervision of the said Election Officer. 1.2. According to Petitioner, out of a total membership strength of 354 AITUC members, as many as 273 attended the said General Body Meeting. The Election Officer called for nominations for each office, and that for every post, only one nomination was received. Consequently, all the nominated candidates were declared elected unopposed. Petitioner was unanimously elected as President. It is further stated that the entire proceedings of the General Body Meeting, including election process, were videographed, that representatives of leading newspapers were present, and that the election results were widely reported in the print media. Petitioner asserts that due intimation of the conduct of the General Body Meeting and the election of office bearers was furnished to the Management as well as to the concerned Labour Authorities. 1.3. Petitioner asserts that due intimation of the conduct of the General Body Meeting and the election of office bearers was furnished to the Management as well as to the concerned Labour Authorities. 1.3. Petitioner alleges that Respondent No.5, despite being fully aware of the convening of the General Body Meeting and the election process, deliberately chose not to attend the said meeting. It is contended that subsequent thereto, Respondent No.5 submitted false, misleading and fabricated representations to the authorities and the body. According to Petitioner, despite the transparent and duly conducted election Management, questioning the legitimacy of the General Body Meeting and the elected process, the Labour Authorities and the Management failed to take timely steps to recognise the elected body. Aggrieved by such inaction, Petitioner states that he was constrained to file Writ Petition No. 23916 of 2024, wherein this Court directed the authority concerned to verify the list of members who attended the General Body Meeting conducted on 11.07.2024 and to recognise the elected body in accordance with law. Petitioner asserts that despite subsistence of the said interim order, the directions of this Court were not implemented, compelling him to initiate contempt proceedings. 1.4. It is further stated that at the stage of contempt proceedings, Respondent No.5 withdrew his complaints and representations. On the basis of such withdrawal and a joint understanding arrived at between the parties, the 2 nd Respondent issued proceedings dated 03.02.2025 recording that the differences between Petitioner and Respondent No.5 had been amicably settled. The said proceedings also requested the Management to recognise the working committee as it existed in June 2024 and to allow the Union to function accordingly. Petitioner asserts that he acted upon the proceedings dated 03.02.2025 in good faith and, relying on the same, withdrew Writ Petition No. 23916 of 2024 as well as the contempt proceedings initiated for non-compliance of the interim order passed by this Court. It is the specific case of Petitioner that withdrawal of earlier writ petition and contempt proceedings was entirely premised on the assurance and finality conveyed through the proceedings dated 05.02.2025. 1.5. Despite the above, Petitioner states that Respondent No.5 thereafter, instituted O.S. No. 437 of 2025 before the Court of the Principal Senior Civil Judge, Sangareddy, seeking a declaration regarding his status and a consequential injunction. 1.5. Despite the above, Petitioner states that Respondent No.5 thereafter, instituted O.S. No. 437 of 2025 before the Court of the Principal Senior Civil Judge, Sangareddy, seeking a declaration regarding his status and a consequential injunction. It is stated that Respondent No.5 also filed an Application for temporary injunction in the said suit. After hearing the parties, the Civil Court dismissed the interim injunction Application on 09.07.2025, holding that the issues involved required adjudication at trial and that no case for interim relief was made out. Petitioner alleges that immediately after suffering the adverse order in the Interlocutory Application, Respondent No.5 once again approached the 2nd Respondent with a further representation. Acting upon the said representation, the 2 nd Respondent issued the impugned communication dated 17.07.2025, whereby the earlier proceedings dated 03.02.2025 were withdrawn on the ground that the dispute was pending before the Civil Court. Based on the said communication, the Management issued consequential proceedings dated 18.07.2025 withdrawing all trade union facilities, including the Union office and movement passes issued to the office bearers. 1.6. Petitioner contends that the action of the 2 nd Respondent in withdrawing the proceedings dated 03.02.2025 is wholly without jurisdiction, as there is no statutory power conferred upon the authority to review or recall its own proceedings, particularly when such proceedings had already been acted upon by the parties. It is further contended that withdrawal of the proceedings after the Petitioner had altered his position by withdrawing the earlier writ petition and contempt case is arbitrary, unreasonable and violative of the principles of natural justice. 1.7. Petitioner asserts that the impugned actions are vitiated by non-application of mind, are motivated, and constitute an abuse of power, resulting in grave prejudice to the recognised union and its members. It is contended that withdrawal of trade union facilities has caused serious hardship to the Union in discharging its representative functions. Petitioner further asserts that the official Respondents, though falling within the definition of "State" under Article 12 of the Constitution, have acted at the behest of Respondent No.5, thereby failing to discharge their statutory obligations in a fair, impartial and lawful manner. 2. Petitioner further asserts that the official Respondents, though falling within the definition of "State" under Article 12 of the Constitution, have acted at the behest of Respondent No.5, thereby failing to discharge their statutory obligations in a fair, impartial and lawful manner. 2. While issuing notice before admission, by order dated 12.08.2025, stay of operation of the impugned proceedings dated 17.07.2025 and 18.07.2025 issued by Respondents 2 and 4 respectively was granted till the next date of hearing and the said order was extended from time to time. 3. Respondent No.2 - Deputy Commissioner of Labour and Deputy Registrar of Trade Unions, Sangareddy, states that this Writ Petition is misconceived both on facts and in law, as the dispute sought to be projected as an administrative illegality is, in substance, an internal dispute between rival factions of the same trade union. It is contended that the controversy arises out of an intra-union rivalry between Petitioner and Respondent No.5 with regard to recognition, continuance, and authority of office bearers of the BHEL Workers Union, and that no statutory right of Petitioner has been infringed by any action or omission on the part of Respondent No.2. It is stated, the core issue raised by Petitioner pertains to rival claims over leadership and control of the Union, which is essentially a private dispute between members of the same trade union. Such a dispute, according to Respondent No.2, does not involve any breach of statutory duty by the Registrar of Trade Unions and does not attract the writ jurisdiction of this Court under Article 226 of the Constitution. 2.1. It is further submitted that under the scheme and structure of the Trade Unions Act, 1926, the Registrar of Trade Unions is entrusted only with administrative and ministerial functions. These functions are limited to matters such as registration of trade unions, maintenance of statutory records, and recording of particulars relating to office bearers as submitted by the Union from time to time. Respondent No.2 specifically contends that the Act does not confer any adjudicatory or quasi-judicial powers upon the Registrar to decide disputes relating to the validity of elections, legitimacy of General Body Meetings, interpretation of union by-laws, or rival claims of office bearers. It is asserted, disputes involving contested elections, rival General Body Meetings, allegations regarding quorum, authenticity of membership or validity of resolutions are matters involving disputed questions of fact. It is asserted, disputes involving contested elections, rival General Body Meetings, allegations regarding quorum, authenticity of membership or validity of resolutions are matters involving disputed questions of fact. Such issues necessarily require examination of oral and documentary evidence and cannot be resolved through a summary administrative process. Accordingly, such disputes fall squarely within the jurisdiction of the competent Civil Court and are outside the purview of the Registrar under the Trade Unions Act, 1926. At best, the Registrar can conduct a limited and summary verification for the purpose of updating statutory records, but even such verification cannot extend to adjudicating competing claims or deciding the legality of rival elections. 2.2. Respondent No.2 further states that proceedings dated 03.02.2025 were issued purely on the basis of a joint representation submitted by both factions of the Union, namely Petitioner and Respondent No.5. The said joint representation conveyed that disputes between the parties had been amicably resolved in the interest of workers welfare. Respondent No.2 clarifies that proceedings dated 03.02.2025 did not involve any independent adjudication or determination by the authority, but merely recorded the understanding communicated by the parties themselves and requested the Management to take note of the same. Issuance of the said proceedings was thus administrative in nature and entirely dependent upon the continued consent and concurrence of both factions. 2.3. It is further stated that subsequent to the issuance of proceedings dated 03.02.2025, Respondent No.5 withdrew from the said understanding and instituted O.S. No. 437 of 2025 before the Principal Senior Civil Judge, Sangareddy, seeking declaratory and injunctive reliefs with regard to recognition of office bearers. Respondent No.2 submits that once Respondent No.5 resiled from the joint understanding and initiated civil proceedings, the very foundation on which the proceedings dated 03.02.2025 were issued ceased to exist. 2.4. In view of pendency of civil suit, which directly involves adjudication of rival claims to office bearership and recognition within the Union, Respondent No.2 contends that it became legally-impermissible for the authority to continue to act upon or give effect to the proceedings dated 03.02.2025. Respondent No.2 submits that any further action based on the said proceedings would have amounted to interference in a matter that had become sub judice and could have prejudiced the adjudication pending before the Civil Court. Accordingly, Respondent No.2 issued the impugned communication dated 17.07.2025 withdrawing the earlier proceedings dated 03.02.2025. Respondent No.2 submits that any further action based on the said proceedings would have amounted to interference in a matter that had become sub judice and could have prejudiced the adjudication pending before the Civil Court. Accordingly, Respondent No.2 issued the impugned communication dated 17.07.2025 withdrawing the earlier proceedings dated 03.02.2025. It is contended that the said withdrawal was not an exercise of any power of review or reconsideration on merits, but was a necessary administrative step taken to maintain institutional neutrality, to avoid parallel or conflicting decisions, and to ensure that the authority does not overstep its statutory limits while a competent Civil Court is seized of the dispute. 2.5. Respondent No.2 further states that the impugned communication dated 17.07.2025 was issued bona fide, in good faith, and in strict adherence to the limitations imposed by the Trade Unions Act, 1926. It is asserted that the action was guided solely by the principle that statutory authorities must refrain from acting in matters that are sub judice before a judicial forum, particularly when such matters involve disputed questions of fact beyond their jurisdiction. Respondent No.2 denies the allegation that the impugned action is arbitrary. motivated or taken at the behest of Respondent No.5. It is contended that the authority has acted impartially and consistently, and that withdrawal of the proceedings dated 03.02.2025 was a logical and legally-necessary consequence of the changed circumstances brought about by the institution of the civil suit. 2.6. Respondent No.2 therefore, states that no illegality, perversity or jurisdictional error can be attributed to the impugned communication dated 17.07.2025, and that the Writ Petition, insofar as it seeks to compel the authority to act in derogation of the pendency of civil proceedings and beyond its statutory powers, is not maintainable and is liable to be dismissed. 3. Respondents 3 and 4 state that they have been unnecessarily dragged into what is essentially an internal dispute between rival factions of a recognized trade union. It is contended that BHEL is a Public Sector Undertaking and an employer, and that it does not possess any statutory authority or jurisdiction under the Trade Unions Act, 1926 to adjudicate disputes relating to the validity of General Body Meetings, election of office bearers, or rival claims within a trade union. It is contended that BHEL is a Public Sector Undertaking and an employer, and that it does not possess any statutory authority or jurisdiction under the Trade Unions Act, 1926 to adjudicate disputes relating to the validity of General Body Meetings, election of office bearers, or rival claims within a trade union. It is stated, the Management has consistently maintained a neutral position throughout the dispute and has refrained from recognizing either faction once rival claims emerged. It is stated, upon receipt of the communication dated 17.07.2025 from Respondent No.2, wherein it was specifically indicated that earlier proceedings dated 03.02.2025 stood withdrawn in view of the dispute being sub judice before the civil Court, the Management was left with no option but to act in accordance with the said communication. The consequential proceedings dated 18.07.2025, whereby trade union facilities including the Union office and movement passes of office bearers were kept in abeyance, were issued purely in deference to the statutory authority and not on any independent assessment or preference. 3.1. Respondents 3 and 4 further contended that continuation of trade union facilities to any one faction during the pendency of a civil suit involving rival claims would have exposed the Management to allegations of bias and could have aggravated industrial unrest within the establishment. It is asserted that temporary withdrawal of facilities was a precautionary administrative measure intended solely to preserve industrial peace, discipline and neutrality, and was neither punitive nor intended to undermine the recognized status of the Union. It is further stated, Management has, at all times, acted in conformity with the Code of Discipline and the communications received from the Labour Authorities. They deny the allegation that they acted at the behest of Respondent No.5 or that they exercised any discretion independently in the matter. According to them, the impugned action was a direct and inevitable consequence of withdrawal of proceedings by Respondent No.2 and the pendency of civil litigation. 4. Respondent No.5, on the other hand, states that the present dispute has arisen solely due to the unilateral and arbitrary actions of Petitioner in the internal administration of the Union. It is contended that after the Union was declared as the Majority Union, Petitioner failed to follow democratic norms and did not convene General Body Meetings in a transparent manner or involve the Executive Committee in decision-making. It is contended that after the Union was declared as the Majority Union, Petitioner failed to follow democratic norms and did not convene General Body Meetings in a transparent manner or involve the Executive Committee in decision-making. It is alleged, Petitioner dissolved the existing Executive Committee on his own and sought to concentrate all decision- making powers in himself, contrary to the established practices and the by-laws of the Union. Respondent No.5 further contends that in view of growing dissatisfaction among the workers, a General Body Meeting was convened by him on 28.06.2024, wherein the functioning of Petitioner was discussed and a decision was taken to elect a new Executive Body. According to him, the said meeting reflected the will of a substantial section of the Union membership, and resolutions passed therein were duly communicated to the Management and the Labour Authorities. 4.1. It is the specific case of Respondent No.5 that the rival claims arising out of the General Body Meetings allegedly held on 28.06.2024 and 11.07.2024 involve serious disputed questions of fact, including issues relating to the validity of notices, quorum, participation of members, authenticity of signatures, and legitimacy of the election process. Such disputed factual issues, it is contended, cannot be resolved in proceedings under Article 226 of the Constitution of India, which are summary in nature, and require adjudication on evidence before a competent Civil Court 4.2. Respondent No.5 further states that he was compelled to institute O.S. No. 437 of 2025 before the Principal Senior Civil Judge, Sangareddy, seeking appropriate declaratory and injunctive reliefs, as the Labour Authorities and the Management could not lawfully decide the intra-union dispute. It is contended that once the civil Court has been seized of the matter, parallel proceedings before this Court under Article 226 are impermissible, particularly when the reliefs sought in the writ petition substantially overlap with the reliefs claimed in the civil suit. He therefore, contends that this Writ Petition is not maintainable; the impugned actions of Respondents 2 to 4 are justified and legally-sustainable and that any interference by this Court, at this stage, would amount to pre-empting the adjudication pending before the Civil Court. 5. In his reply, Petitioner states that the attempt to characterise the present dispute as a mere intra-union rivalry is a deliberate oversimplification intended to deflect judicial scrutiny from the manifest illegality and arbitrariness in the impugned actions. 5. In his reply, Petitioner states that the attempt to characterise the present dispute as a mere intra-union rivalry is a deliberate oversimplification intended to deflect judicial scrutiny from the manifest illegality and arbitrariness in the impugned actions. While it is not disputed that differences arose between Petitioner and Respondent No.5, this Writ Petition is not directed against any rival union claim per se, but against the unlawful withdrawal of duly issued proceedings by a statutory authority and the consequential deprivation of trade union facilities by the Management, in violation of settled principles of administrative law and natural justice. 5.1. Petitioner states that Respondent No.2 failed to appreciate that the challenge in this Writ Petition is not to any refusal to adjudicate rival claims of office bearers, but to the arbitrary withdrawal of proceedings dated 03.02.2025, which were issued by Respondent No.2 himself after due application of mind and were acted upon by Petitioner to his serious detriment. It is contended, once the statutory authority issued proceedings dated 03.02.2025 recording an amicable settlement and requesting the Management to recognise the working committee, the authority became functus officio in respect of the said proceedings and could not have unilaterally withdrawn the same in the absence of any statutory power of review or recall. 5.2. Petitioner further states that reliance placed by Respondent No.2 on the limited scope of powers under the Trade Unions Act, 1926 is misplaced in the facts of the present case. While it is conceded that the Registrar of Trade Unions does not exercise adjudicatory or quasi-judicial powers to decide rival claims of office bearers, Petitioner states that the impugned action does not involve any such adjudication. Instead, proceedings dated 03.02.2025 were administrative in nature and were issued on the basis of representations made to the authority. Having exercised such administrative power and having induced Petitioner to alter his position irreversibly by withdrawing a pending writ petition and contempt proceedings, Respondent No.2 could not have resiled from the same on a subsequent change of stance by Respondent No.5. 5.3. Petitioner emphatically denies the contention that proceedings dated 03.02.2025 were provisional or contingent in nature. On the contrary, the said proceedings expressly recorded that disputes had been amicably resolved and requested the Management to take necessary steps to recognise the working committee. 5.3. Petitioner emphatically denies the contention that proceedings dated 03.02.2025 were provisional or contingent in nature. On the contrary, the said proceedings expressly recorded that disputes had been amicably resolved and requested the Management to take necessary steps to recognise the working committee. Petitioner states that the authority never indicated that the said proceedings were subject to further verification, review, or withdrawal Acting on the said proceedings, Petitioner withdrew Writ Petition No. 23916 of 2024 and the contempt case, thereby giving up valuable legal remedies that had already fructified in the form of interim orders in his favour. 5.4. Petitioner states further that subsequent institution of O.S. No. 437 of 2025 by Respondent No.5 cannot retrospectively invalidate or nullify the proceedings dated 03.02.2025. It is contended that a unilateral act of Respondent No.5 in approaching the Civil Court, particularly after having withdrawn his complaints and representations earlier, cannot confer jurisdiction upon Respondent No.2 to withdraw an order already passed and acted upon. Petitioner states that pendency of a civil suit does not automatically render prior administrative orders void or non est, nor does it empower the authority to undo its own concluded actions. It is stated, the plea of sub judice advanced by Respondent No.2 is misconceived and legally-untenable. It is contended, civil suit instituted by Respondent No.5 seeks declaratory and injunctive reliefs inter se the parties and does not, in any manner, challenge the proceedings dated 03.02.2025. In the absence of any stay or injunction granted by the Civil Court restraining Respondent No.2 or the Management from acting upon the proceedings dated 03.02.2025, withdrawal of the said proceedings on the ground of pendency of suit is wholly arbitrary and without authority of law. 5.5. Petitioner further contends that Respondent No.2 has incorrectly characterized withdrawal of proceedings dated 03.02.2025 as a mere administrative act to maintain neutrality. It is stated, in substance and effect, impugned communication dated 17.07.2025 amounts to a review and reversal of an earlier concluded decision, which has serious civil consequences. Such an action, even if styled as administrative, cannot be undertaken in the absence of express statutory power, and certainly not without affording an opportunity of hearing to the Petitioner, whose rights and interests stood materially affected. Such an action, even if styled as administrative, cannot be undertaken in the absence of express statutory power, and certainly not without affording an opportunity of hearing to the Petitioner, whose rights and interests stood materially affected. Petitioner states that the impugned action has directly resulted in the Management withdrawing all trade union facilities, including the Union office and movement passes, thereby crippling the functioning of the recognized union. Such drastic consequences, it is contended, could not have been visited upon the Petitioner and the Union members without adherence to the principles of natural justice. Respondent No.2, despite being aware that Petitioner had acted upon the proceedings dated 03.02.2025, did not issue any notice or afford any opportunity of hearing before issuing the impugned withdrawal dated 17.07.2025. 5.6. Petitioner categorically denies the allegation that Respondent No.2 acted bona fide or neutrally. The sequence of events clearly demonstrates that immediately after Respondent No.5 suffered an adverse order in the interlocutory application in O.S. No. 437 of 2025, he approached Respondent No.2 with a fresh representation, and impugned withdrawal followed in undue haste. Petitioner states that the impugned action has the effect of indirectly granting Respondent No.5 what he failed to secure from the Civil Court. It is further stated, Respondent No.2 cannot selectively invoke the limitations of his statutory powers to justify withdrawal of the proceedings dated 03.02.2025, while ignoring the fact that the same authority had earlier exercised administrative power to issue those proceedings in the first place. Having acted within his authority earlier, Respondent No.2 cannot subsequently disown responsibility on the specious plea of lack of jurisdiction. 5.7. Petitioner reiterates that the present Writ Petition does not seek adjudication of rival claims of office bearers or resolution of disputed questions of fact. The limited grievance is against the arbitrary, illegal and unjust withdrawal of proceedings dated 03.02.2025 and the consequential withdrawal of trade union facilities, which have caused severe prejudice to the Union and its members. Petitioner therefore, states that the impugned communication dated 17.07.2025 is vitiated by lack of jurisdiction, non-application of mind, violation of principles of natural justice, and arbitrariness, and that the same warrants interference by this Court under Article 226 of the Constitution of India. 6. Petitioner therefore, states that the impugned communication dated 17.07.2025 is vitiated by lack of jurisdiction, non-application of mind, violation of principles of natural justice, and arbitrariness, and that the same warrants interference by this Court under Article 226 of the Constitution of India. 6. Heard Sri B. Shiva Kumar, learned counsel for petitioner, learned Government Pleader for Labour on behalf of Respondents 1 and 2, Sri B. Manoj Kumar, learned counsel for Respondents 3 and 4 and Sri Jalli Kanakaiah, learned Senior Counsel on behalf of Sri Jalli Narender, learned counsel for Respondent No.5. 7. At the outset, it is necessary to delineate the true scope of the controversy. Though the dispute has its genesis in an internal disagreement between Petitioner and Respondent No.5 regarding the leadership of the BHEL Workers Union, the lis before this Court is not the one seeking adjudication of rival claims to office-bearership nor is it one requiring determination of the validity of General Body Meetings or elections. The limited and specific challenge in the present Writ Petition is to the legality of the proceedings dated 17.07.2025 issued by Respondent No.2 withdrawing the earlier proceedings dated 03.02.2025, and the consequential proceedings dated 18.07.2025 issued by Respondents 3 and 4 withdrawing all trade union facilities. 8. There is no serious dispute on record that Respondent No.2, acting in his capacity as Deputy Commissioner of Labour and Deputy Registrar of Trade Unions, issued proceedings dated 03.02.2025 on the basis of a joint representation submitted by Petitioner and Respondent No.5, recording that disputes between them had been amicably resolved and requesting the Management to recognize the working committee as it stood in June 2024. It is also undisputed that acting upon the said proceedings, Petitioner withdrew Writ Petition No. 23916 of 2024 as well as the contempt proceedings initiated for non-compliance of the interim directions earlier granted by this Court. 9. The core question that arises for consideration is whether Respondent No. 2 was justified in unilaterally withdrawing the proceedings dated 03.02.2025 by issuing the impugned communication dated 17.07.2025, and whether such withdrawal could validly form the basis for the Management to withdraw all trade union facilities. 10. 9. The core question that arises for consideration is whether Respondent No. 2 was justified in unilaterally withdrawing the proceedings dated 03.02.2025 by issuing the impugned communication dated 17.07.2025, and whether such withdrawal could validly form the basis for the Management to withdraw all trade union facilities. 10. Respondent No.2 has strenuously contended that under the Trade Unions Act, 1926, the Registrar of Trade Unions performs only administrative and ministerial functions and has no jurisdiction to adjudicate disputes relating to rival claims of office bearers, and that such disputes must necessarily be resolved by the civil Court. This proposition, as a general statement of law, is unexceptionable. It is well-settled that the Registrar cannot conduct a full-fledged adjudication or decide disputed questions of fact involving elections, quorum, or validity of resolutions. However, the difficulty with the stand of Respondent No.2 lies not in the exposition of the limits of his statutory powers, but in the manner in which those limits are sought to be invoked after the authority has already exercised administrative power and induced the Petitioner to act upon it. The proceedings dated 03.02.2025 were not issued by the authority under any coercion or mistake apparent on the face of the record. They were issued consciously, recording a settlement placed before the authority by both factions, and they carried clear administrative consequences, including a request to the Management to recognize the working committee. 11. Once such proceedings were issued and acted upon, the Authority could not have withdrawn them in the absence of any express statutory power of review or recall, particularly when the withdrawal visited Petitioner with serious civil consequences. The plea that the Authority acted merely to maintain neutrality or to avoid interference in a sub judice matter does not, by itself, confer jurisdiction to undo an administrative action that had already attained finality. The pendency of O.S. No. 437 of 2025, instituted by Respondent No.5 subsequent to issuance of proceedings dated 03.02.2025, cannot retrospectively invalidate those proceedings. The civil suit, as is evident from the record, concerns declaratory and injunctive reliefs between rival factions and does not contain any order restraining Respondent No.2 or the Management from acting upon the proceedings dated 03.02.2025. In the absence of any interdiction by the Civil Court, invocation of the doctrine of sub judice by Respondent No.2 to justify withdrawal of the earlier proceedings is legally unsustainable. 12. In the absence of any interdiction by the Civil Court, invocation of the doctrine of sub judice by Respondent No.2 to justify withdrawal of the earlier proceedings is legally unsustainable. 12. Equally significant is the fact that the impugned communication dated 17.07.2025 was issued without putting Petitioner on notice and without affording any opportunity of hearing, despite the authority being fully aware that Petitioner had altered his position irreversibly by withdrawing a Writ Petition and contempt proceedings on the strength of the earlier order. Even an administrative action, when entails serious civil consequences, must conform to the principles of natural justice. Withdrawal of proceedings dated 03.02.2025, which directly resulted in deprivation of trade union facilities, undoubtedly, had grave consequences for the Union and its members. 13. The action of Respondent 3 and 4 in withdrawing all trade union facilities, though justified by them as consequential and precautionary, cannot be viewed in isolation. Their action is entirely founded on the impugned communication issued by Respondent No.2. Once the foundation itself is found to be legally infirm, the superstructure built upon it cannot be sustained. This Court is conscious of the submission that the underlying intra-union dispute is pending before the Civil Court and that this Court should not adjudicate upon rival claims of office bearers. This Court has consciously refrained from doing so. The interference warranted in the present case is confined to correcting an administrative illegality and ensuring that a statutory authority does not act arbitrarily or in excess of jurisdiction under the guise of neutrality. 14. The contention that the Authority has no power to adjudicate disputes cannot be selectively invoked to justify withdrawal of an order which the same authority had earlier issued within its administrative domain. The law does not permit a statutory authority to approbate and reprobate in this manner, particularly when third-party rights and legitimate expectations have intervened. Viewed thus, this Court is of the considered opinion that the impugned communication dated 17.07.2025 issued by Respondent No.2 is vitiated by lack of jurisdiction, non-application of mind, and violation of the principles of natural justice, and that the consequential proceedings dated 18.07.2025 issued by Respondents 3 and 4 cannot be sustained. For the reasons stated above, the Writ Petition deserves to be allowed. 15. For the reasons stated above, the Writ Petition deserves to be allowed. 15. Accordingly, the proceedings dated 17.07.2025 issued by Respondent No.2 and the consequential proceedings dated 18.07.2025 issued by Respondents 3 and 4 are hereby set aside. Respondents 2 to 4 are directed to extend all trade union facilities to Petitioner Union in terms of the proceedings dated 03.02.2025, subject to the outcome of O.S. No. 437 of 2025 pending before the competent Civil Court. It is made clear that this Court has not expressed any opinion on the merits of the rival claims between Petitioner and Respondent No.5, and the civil Court shall decide the said suit independently, uninfluenced by any observations made herein. No costs. 16. Pending miscellaneous Applications, if any, shall stand closed.