Definition of “Industry” under Indian Law with Case Laws
1. Statutory Definition:
•Section 2(j) of the Industrial Disputes Act, 1947:
•“Industry” means:
•Any systematic activity carried on by cooperation between an
employer and his workmen (whether directly or indirectly), for the
production, supply, or distribution of goods or services with a view to
satisfy human wants or wishes, excluding spiritual or religious services.
•It includes any activity related to promotion, sales, and distribution
of goods or services.
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2. Landmark Case Laws:
(A) Bangalore Water Supply and Sewerage Board v. A. Rajappa, AIR 1978
SC 548
•Facts: The case involved whether statutory bodies, including a
water supply board, fell within the ambit of “industry” under the Industrial
Disputes Act, 1947.
•Judgment: The Supreme Court laid down a triple test for
determining an industry:
•(i) Systematic Activity: Organized and regulated business activity.
•(ii) Cooperation between Employer and Employee: Engaged for the
production, supply, or distribution of goods and services.
•(iii) Satisfaction of Human Wants: Aimed at fulfilling human needs
(excluding religious/spiritual wants).
•Ratio: A broad and inclusive interpretation was given to the term
“industry,” bringing several public utility services and statutory bodies
under its scope.
•Impact: It overruled earlier restrictive decisions and expanded the
definition of “industry.”
(B) Hospital Mazdoor Sabha v. State of Bombay, AIR 1960 SC 610
•Facts: Whether a hospital run by the government constituted an
industry.
