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In National Textile Workers' Union v. P.R. Ramakrishnan, (1983) 1 SCC 228, the Supreme Court held that:

Aa workers' union can NEVER be heard in any winding-up proceeding under the Companies Act (cf. National Textile Workers' Union v. P.R. Ramakrishnan, (1983) 1 SCC 228)
Bwinding-up proceedings can be initiated only by creditors, never by workers (cf. National Textile Workers' Union v. P.R. Ramakrishnan, (1983) 1 SCC 228)
Cworkers of a company have the right to be heard in a winding-up petition under Section 433 Companies Act 1956 (Now Sections 270-275 / IBC)
Dthe National Company Law Tribunal has no jurisdiction over winding-up matters in India (cf. National Textile Workers' Union v. P.R. Ramakrishnan, (1983) 1 SCC 228)
Answer & Solution
Correct answer: C. workers of a company have the right to be heard in a winding-up petition under Section 433 Companies Act 1956 (Now Sections 270-275 / IBC)
1. In National Textile Workers' Union v. P.R. Ramakrishnan (1983), the Supreme Court (per Bhagwati J.) recognised the WORKERS' LOCUS to be heard in a winding-up proceeding. 2. The Court reasoned that workers have a vital stake in the company's survival; their interests merit consideration alongside creditors and shareholders. 3. The principle has been carried forward in subsequent winding-up cases and into the Insolvency and Bankruptcy Code, 2016 framework (Section 30(2)(b) IBC mandates that workmen's dues be treated specifically). 4. The judgment is part of Indian corporate law's stakeholder-pluralism trajectory. 5. Hence option B is correct. _Source: Companies Act 2013 (Act 18 of 2013), Govt. of India MCA — National Textile Workers' Union v. P.R. Ramakrishnan, (1983) 1 SCC 228_
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