Counsel for the appellant company, in support of the appeal, raised the following points : (1) Was it possible for the respondent union to validly espouse the cause of respondent 3 when he was not a member at the date when his service was terminated Even if it was, was there in fact an espousal so as to convert his individual dispute into an industrial dispute ? (2) Do the words "at any time" in section 4(k) of the Act have any limitations, or can the Government refer a dispute, for adjudication after the lapse of about six years, as in this case, after the accrual of the cause of the dispute ? (3) In what circumstances can the Government refer such a dispute for adjudication after it has once refused to do so ? The definition of 'industrial dispute ' in section 2(l).of the Act is in the same language as that in section 2(k) of the .