Section 71 in Bombay Industrial Relations Act, 1946
71. Dispute to be referred to Labour Court and Industrial Court if no arbitrator appointed. - Notwithstanding anything contained in this Chapter, if no provision has been made in any submission for the appointment of an arbitrator or where by reason of any circumstance no arbitrator is appointed, such dispute shall be referred to the arbitration of a Labour Court or the Industrial Court, as the [State] Government may determine.
