The Standing Orders certified under the Industrial Employment Standing Orders Act, 1946'(for brevity's sake to be referred to as the 1946 Act) not only contain a clause that absence without leave, or overstaying of leave would amount to misconduct for which there is a'penalty provided. Invariably such-Standing Orders also contain a clause to the effect that if the employee remained absent without sanctioned leave or beyond the-period of leave originally granted he would' lose his lien unless he returned within a prescribed number of days (normally fixed at 8 days) and explained to the satisfaction of the manager ment reasons for his absence. Usually this losing lien was interpreted as losing job, abandoning employment etc. This clause always fell heavily on the employee in respect of the security of employment which in a country like ours brings "economic death' Two 'Supreme Court Cases In support of the theory of the employee losing lien two Supreme Cou ....