Supreme Court’s Refusal to Examine ‘Industry’ Definition Under the Industrial Relations Code, 2020: Revisiting the Legacy of Bangalore Water Supply
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...