The Industrial Disputes Act 1947 (IDA) conferred the power of reference in the realm of industrial dispute resolution to any relevant adjudicatory body, namely, to the Board of Conciliation, the court of inquiry, the labour court and the tribunal. The power of reference inscribed in Section 10 of the Act entailed that the appropriate Government upon coming to an opinion that an industrial dispute exists, or upon apprehending such dispute, is entitled to refer the dispute or any matter appearing to be connected thereto to the relevant adjudicatory forum