Industry: Under Section S-2(j) Of The Industrial Disputes Act, 1947

In the Case, State of Uttar Pradesh Vs. Jai Bir Singh, a nine-Judge Bench led by Chief Justice Surya Kant considered the meaning of “industry” under Section 2(j) of the Industrial Disputes Act, 1947, and the correctness of the triple test laid down in Bangalore Water Supply & Sewerage Board Vs. A. Rajappa (1978).

In this Case, the Court had framed the following questions of laws: (i) Whether the definition of ‘industry’ under Section 2(j) of the Industrial Disputes Act, 1947 (ID Act) should be read restrictively?; (ii) Whether the majority judgment in the Bangalore Water Supply case was a unanimous judgment?; (iii) Whether a restrictive reading of ‘industry’ under the ID Act will be in line with the objective of the ID Act to promote a harmonious relationship between the employer and the employee?

In this Case the Court has Held that the triple test laid down in Bangalore Water-Supply & Sewerage Board v R. Rajappa. (1978) will determine all pending industrial disputes.

Both the Judgments, Jai Bir Singh (Supra) and Bangalore Water Supply & Sewerage Board (Supra) and the highlights of the said judgments are as follows:

1. Bangalore Water-Supply & Sewerage Board Vs. R. Rajappa- 1978- 7JB Supreme Court Of India Judgment Dated- 21.02.1978- 1978 AIR 548= 1978 SCR (3) 207- SC had laid in this case the following TRIPLE TEST, holding that an activity qualifies as an industry if it satisfies three main conditions: (i) Systematic and organized activity, (ii) cooperation between the employer and the employees (iii) production or distribution of goods and services calculated to satisfy human wants or wishes [Read Full Judgment].

2. Jai Bir Singh- State of Uttar Pradesh Vs. Jai Bir Singh- Citation: 2026 INSC 897- 9JB Supreme Court Of India Judgment Dated- 20.08.2026- A nine-judge Bench of the Supreme Court unanimously held that the TRIPLE TEST laid down in Bangalore Water-Supply & Sewerage Board Vs. R. Rajappa. (1978) will determine all pending industrial disputes [Read Full Judgment].

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