Chapter V-B of the Industrial Disputes Act, 1947 (hereinafter referred to as the Act) introduced in 1976, under the emergency regime, has introduced a rigid exit policy in the country, by making it obligatory for the employers, employing 300 or more than 300 workers, to seek the permission of the appropriate Government before they can lay-off, retrench, or close their industrial establishment. The 1982 Amendment to the Act has made this exit policy more rigid by making this chapter, now applicable to employers employing 100 or more than 100 workman in their industrial establishment. Section 25-O of the Act deals with the provision with regard to closure of undertaking of an industrial establishment under Chapter V-B. This section was amended in the year 1982, because of the Supreme Court Judgment in the famous case of Excel Wear v. Union of India, AIR 1979 SC 25 : 1978 Lab IC 1537, in which it was held that the section is unconstitutional for violating Article 19(1)(g) of the Indian ....