How many kinds of settlement of disputes have been finalised by the Supreme Court in Tata Chemicals v/s…

In Tata Chemicals Ltd. v. Its Workmen (1978), the Supreme Court read section 2(p) of the Industrial Disputes Act, 1947 and held that it "envisages two categories of settlement": one arrived at in the course of conciliation proceedings, and one arrived at by a written agreement between the employer and workmen otherwise than in conciliation.

Under section 18, a conciliation settlement binds all parties to the dispute and all present and future workmen, while the other kind binds only the parties who signed it. The Industrial Disputes Act, 1947 has since been replaced by the Industrial Relations Code, 2020, whose definition of "settlement" keeps the same two categories.