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I. Introduction A nine-judge Constitution Bench of the Supreme Court of India , led by Chief Justice of India Surya Kant , has clarified that it will not examine the definition of “industry” under the Industrial Relations Code, 2020 while reviewing the correctness of the landmark 1978 judgment in Bangalore Water Supply v A Rajappa . Instead, the Court has confined its inquiry to determining whether the interpretation of “industry” under the earlier statutory regime—specifically the Industrial Disputes Act, 1947—was correctly decided in 1978. II. Background: The 1978 Bangalore Water Supply Judgment The decision in Bangalore Water Supply v. A. Rajappa (1978) remains one of the most significant rulings in Indian labour law. The Court interpreted Section 2(j) of the Industrial Disputes Act, 1947 expansively and introduced a “triple test” to determine what constitutes an “industry”: Systematic activity Cooperation between employer and employee Production or distribution of goods and se...

Introduction: A Constitutional Reassessment of Labour Law The Supreme Court of India is set to revisit one of the most consequential questions in Indian labour jurisprudence: What constitutes an “industry”? A nine-judge Constitution Bench , scheduled to hear the matter on March 17 and 18 , will reconsider the expansive interpretation laid down in the landmark Bangalore Water Supply case (1978) . Chief Justice of India Surya Kant described the reference as the first matter referred to a nine-judge bench in the Court’s history , highlighting its constitutional and institutional significance. The outcome will have far-reaching implications for labour rights, public administration, educational institutions, charities, and government departments . Background of the Reference: State of Uttar Pradesh v. Jai Bir Singh Origin of the Reference The lead case State of Uttar Pradesh v. Jai Bir Singh seeks reconsideration of the definition of “industry” under labour laws. In 2017 , a seven-judge b...