DEFINITION OF “INDUSTRY” UNDER LABOUR LAW

DEFINITION OF “INDUSTRY” UNDER LABOUR LAW — THE 2026 SUPREME COURT CONTROVERSY

1. Background of the Dispute

• The expression “industry” is crucial in labour law because it determines which establishments and workers receive protection under industrial-dispute legislation.
• For nearly five decades, the leading interpretation came from the Supreme Court’s seven-judge decision in Bangalore Water Supply & Sewerage Board v. A. Rajappa (1978).
• That judgment gave the term a deliberately wide meaning and brought many organised employer–employee activities within labour-law protection. (Sci API)

2. The 1978 “Triple Test”

• Bangalore Water Supply treated an activity as an industry when there was systematic activity, organised through cooperation between employer and employees, for production or distribution of goods or services satisfying human wants.
• Profit motive was not essential.
• Educational, charitable, research, cooperative, professional and many public-service activities could therefore fall within the definition.
• Core sovereign functions such as defence, law and order and similar strictly governmental functions were generally excluded. (Sci API)