( 1 ) THE petitioner is sugar manufacturing company. It has laid off its workmen from the closing of working hours on 13th April, 2001 as per the notice at Annexure-A, The 2nd respondent-Association of workers of petitioner-Company complained to the Labour Department that the managment illegally declared lay-off without paying lay-off compensaition and thereby violated Section 25-M of the Industrial Disputes Act, 1947 (hereinafter referred to as 'the Act' ). The Labour Department issued a notice to the petitioner as per Annexure-B, for which the management has replied as per Annexure-C. Since the reply of the management was not tenable, the Commissioner of Labour issued the impugned recovery certificate at Annexure-D for a total sum of Rs. 51,56,746. 00. The petitioner is seeking to quash the same and to declare that petitioner unit as a "seasonal establishment".

( 2 ) ELABORATE and detailed statement of objections is filed on behalf of 2nd respondent along with several documents justifying the impugned order and seeking dismissal of the writ petition.

( 3 ) HEARD the learned Counsels for the parties. Mr. S. N. Murthy, learned Counsel for the petitioner vehementl