20/08/2026
โ๏ธ What exactly is an โIndustryโ? The Supreme Court has just answered a question that could affect hundreds of pending labour disputes.
The Supreme Courtโs 9-Judge Constitution Bench, in State of U.P. v. Jai Bir Singh, has delivered a significant judgment concerning the interpretation of โindustryโ under Section 2(j) of the Industrial Disputes Act, 1947.
The Court has clarified an important point: For pending proceedings under the Industrial Disputes Act, the definition laid down in the landmark Bangalore Water Supply judgment (Triple Test) continues to govern.
Why does this matter?
Because the definition of โindustryโ determines the applicability of the industrial-dispute framework and the rights and remedies available to workmen.
The Supreme Court has now made it clear that employers and employees involved in pending proceedings under the repealed Industrial Disputes Act cannot seek to reopen those cases merely because the Court has revisited the Bangalore Water Supply jurisprudence.
But there is another crucial point.
๐ The Court has clarified that its interpretation relates to the Industrial Disputes Act, 1947.
The ID Act has since been replaced by the Industrial Relations Code, 2020, which came into effect on 21 November 2025.
Therefore, organisations must carefully distinguish between:
OLD DISPUTES โ Industrial Disputes Act + Bangalore Water Supply principles
NEW REGIME โ Industrial Relations Code, 2020
For HR / IR / Legal professionals and employers, this is more than a constitutional-law development. It is a reminder that the classification of an establishment/activity as an โindustryโ has direct consequences for labour relations, dispute management and compliance strategy.
If your organisation has pending industrial disputes, legacy employment matters or unresolved labour litigation, this judgment deserves immediate attention.
The transition from the Industrial Disputes Act to the Industrial Relations Code also makes this an important time to review your industrial relations framework, policies and dispute strategy.
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