In which one of the following cases is it mandatory for the appropriate Government to make reference of an industrial dispute for adjudication/settlement to the Industrial Tribunal/Labour Court/Arbitration ?

Under the Industrial Disputes Act, 1947, the power of the "appropriate Government" to refer a dispute for adjudication is generally discretionary under Section 10(1). However, the second proviso to Section 10(1) creates a mandatory obligation. It states that where a dispute relates to a public utility service and a notice of strike or lockout under Section 22 has been given, the Government shall make a reference to an appropriate authority (unless it considers the notice frivolous or inexpedient).

The First Schedule of the Act identifies "any system of public conservancy or sanitation" as a public utility service—functions typically performed by a municipality. Therefore, disputes in a municipality trigger this mandatory provision. In contrast, disputes involving national importance (Section 10(1A)) or general matters in Schedules II and III (Options A and B) remain within the government's discretionary "may" power.