"Supreme Court dissent warns against narrowing 'industry' definition under labour code"
Industrial Relations Code, 2020 (IRC)
One of four Labour Codes consolidating the Industrial Disputes Act 1947, Trade Unions Act, and Industrial Employment (Standing Orders) Act.
Bangalore Water Supply judgment (1978)
Supreme Court ruling giving 'industry' an expansive definition covering non-profit and government establishments.
India's labour law framework has its roots in colonial-era legislation. The Trade Disputes Act, 1929 introduced a system of tribunals and restricted strikes. After Independence, the Industrial Disputes Act, 1947 (IDA) became the cornerstone of labour relations. It defined 'industry' broadly to determine which establishments and workers fell within its protective ambit. The IDA provided mechanisms for conciliation, arbitration, and adjudication of disputes between employers and workers.
A landmark moment came in 1978, when the Supreme Court decided Bangalore Water Supply and Sewerage Board v. R. Rajappa. A seven-judge bench gave 'industry' an expansive definition. It held that any systematic activity organised with the cooperation of employer and employee for the production or distribution of goods or services, whether or not profit was the motive, qualified as an 'industry'. This definition extended labour protections to hospitals, educational institutions, and government departments. It served as a protective shield for workers across a wide range of establishments for nearly five decades.
India's economic liberalisation from the early 1990s brought new pressures. Private sector growth, outsourcing, and the rise of contract labour created new vulnerabilities for workers. The broad 1978 definition became increasingly important as a counterweight to growing corporate bargaining power. The government eventually consolidated 29 central labour laws into four Labour Codes, one of which is the Industrial Relations Code, 2020 (IRC). The IRC replaced the IDA and redefined 'industry' under Section 2(p).
The definition of 'industry' is not a technical formality. It determines which workers can raise an industrial dispute, access labour tribunals, claim protection against unfair dismissal, and organise collectively. A narrow definition excludes large categories of workers from these protections. A broad definition brings more workers under the law's umbrella.
The Bangalore Water Supply judgment of 1978 was deliberately expansive. It rejected the view that 'industry' required a profit motive or a purely commercial character. The court reasoned that the welfare of workers should not depend on whether their employer ran a business or a public service. This made the judgment a bulwark for workers in hospitals, universities, municipalities, and government undertakings, sectors that expanded rapidly after liberalisation.
The Industrial Relations Code, 2020 is one of four Labour Codes enacted to simplify India's complex labour law architecture. …
The Trade Disputes Act of 1929 provided for
Who among the following were the founders of the "Hind Mazdoor Sabha" established in 1948 ?
With reference to the Industrial Relations Code, 2020 (IRC), consider the following statements:
1.The IRC consolidates the Industrial Disputes Act 1947, the Trade Unions Act 1926, and the Industrial Employment (Standing Orders) Act 1946.
2.The definition of 'industry' under the IRC is contained in Section 2(p).
3.The Supreme Court's nine-judge bench held that the Bangalore Water Supply judgment (1978) is binding precedent for interpreting 'industry' under the IRC.
Which of the statements given above is/are correct?
The Trade Disputes Act of 1929, enacted during British rule in India, is historically significant because it:
1.Introduced a system of industrial tribunals for dispute resolution.
2.Granted workers the right to participate in management decisions.
3.Imposed a ban on strikes in certain categories of employment.
Which of the statements given above is/are correct?
The dissenting opinion in the nine-judge bench ruling on the definition of 'industry' under the Industrial Relations Code, 2020 relied on the English case Greaves v. Tofield (1880) to argue that:
Assertion (A): The Bangalore Water Supply and Sewerage Board v. R. Rajappa (1978) judgment extended the definition of 'industry' to cover hospitals, educational institutions, and government departments.
Reason (R): The Supreme Court held that a profit motive is essential for an establishment to qualify as an 'industry' under the Industrial Disputes Act, 1947.
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