As per case facts, Rameshwar Manjhi, a coal cutter, suffered an accident resulting in his leg's amputation. Despite a medical recommendation for light duty, the management terminated his services with ... compensation. He initiated a dispute under Section 2A of the Industrial Disputes Act, 1947, which was referred to an Industrial Tribunal for adjudication. During the proceedings, the workman passed away. His son sought substitution to continue the case, but the management contested it, claiming the dispute became infructuous upon the workman's death. The Tribunal sided with the management, rejecting the substitution application. The question arose whether an industrial dispute concerning termination of service survives when the workman dies during its pendency, and if the legal heirs can continue the proceedings before the Tribunal. Finally, the Supreme Court ruled that such a reference does not become infructuous or abate upon the workman's death. It affirmed that the heirs and legal representatives are entitled to continue the matter, as monetary benefits like back-wages can still be claimed, and the dispute's resolution can have broader implications for industrial peace and other workmen, thus limiting the application of the maxim 'actio personalis moritur cum persona' in this context.