As per case facts, the appellant, a Medical Representative (Sales Promotion Officer) employed since 1997, was suspended and later terminated for false reporting. He filed a complaint regarding changes in ... service conditions and then an application under Section 33A before the Labour Court. This was registered as a reference, but a Single Judge set aside the order and granted liberty to file a fresh application. The appellant then filed under Section 10, leading to a reference being passed. The management challenged this, arguing that a Medical Representative is not a "workman" under the Industrial Disputes Act. The Single Judge upheld this, dismissing the appellant's petition and review. The question arose whether a Medical Representative/Sales Promotion Officer falls within the definition of "workman" under the Industrial Disputes Act, 1947, given their duties involve sales promotion. Finally, based on a Constitutional Bench judgment and various High Court decisions, the Supreme Court's consistent view is that persons engaged in sales promotion work, such as Medical Representatives, do not perform duties that fall within the categories of manual, supervisory, technical, or clerical work as defined for a "workman". Therefore, they are not considered "workmen" under the Industrial Disputes Act, and disputes related to them cannot be entertained by the Labour Court. The appeal was thus dismissed.