Bangalore Water Supply and Sewerage Board v. A. Rajappa

Facts

• Bangalore Water Supply and Sewerage Board was a statutory body providing water supply and sewerage services to the city
• Workers of the Board raised an industrial dispute regarding service conditions
• The Board contended it was NOT an "industry" because: (a) it was a statutory/government body; (b) it performed a public/governmental function; (c) there was no profit motive
• Previous decisions (Hospital Mazdoor Sabha 1960 and Safdarjung Hospital 1970) had created conflicting approaches
• Seven-judge bench constituted to settle the law definitively

Issues

1. What is the correct test for determining whether an activity constitutes an "industry" under S.2(j) of the Industrial Disputes Act, 1947?
2. Whether profit motive, governmental nature, or charitable character excludes an establishment from being an "industry"
3. Whether a municipal water supply board constitutes an "industry"

Held

• The Triple Test determines whether an activity is an "industry":
• Systematic activity: organised, not casual or isolated
• Cooperation between employer and employee: not self-employment or pure partnership
• For production, supply, or distribution of goods or services satisfying human wants (not merely spiritual/religious)
• If all three elements are satisfied, the activity IS an industry regardless of:

Ratio Decidendi

The definition of "industry" is to be construed broadly to give maximum coverage to labour law protections. The dominant nature test (Safdarjung) and the liberal-without-limits test (Hospital Mazdoor Sabha) are both supplanted by the Triple Test, which provides a clear, workable standard. Profit motive is irrelevant because the purpose of industrial law is to protect workers, and workers in non-profit organizations need protection equally.