SC Revisits the Definition of ‘Industry’ in Indian Labour Law

In August 2026, a nine-judge Constitution Bench of the Supreme Court delivered a fractured verdict on the interpretation of ‘industry’ as defined under the Industrial Relations Code, 2020.

Background: From Bangalore Water Supply to the Present

  • Section 2(j) of the Industrial Disputes Act, 1947 defines an ‘industry’.
  • In Bangalore Water Supply and Sewerage Board v. A. Rajappa (1978), a seven-judge Bench adopted a broad, worker-oriented interpretation through the “triple test”.
  • Subsequent judgments created uncertainty regarding welfare activities, sovereign functions, hospitals and educational institutions.
  • In State of Uttar Pradesh v. Jai Bir Singh (2005), the issue was referred for reconsideration, eventually reaching a nine-judge ....
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