The landmark judgment of Bangalore Water Supply and Sewerage Board v. A. Rajappa & Others, delivered by the Supreme Court of India in 1978, significantly influenced the interpretation of the term ‘industry’ under the Industrial Disputes Act, 1947. The case cantered on whether the Bangalore Water Supply and Sewerage Board, a statutory body, could be classified as an industry under the Act, thereby making its employees eligible for certain protections and benefits. Prior to this case, the definition of ‘industry’ had been subject to varied interpretations, leading to confusion and inconsistency in its application. The Industrial Disputes Act, 1947, broadly defined ‘industry’ to include any business, trade, undertaking, manufacture, or calling of employers and any calling, service, employment, handicraft, or industrial occupation or avocation of workmen. However, this expansive definition left room for ambiguity, especially concerning statutory bodies and non-profit organizations. In this case, the Bangalore Water Supply and Sewerage Board argued that it was not an industry, emphasizing its statutory duties and public welfare objectives. The Board contended that its primary purpose was to provide essential services, not to engage in profit-making activities typical of private enterprises. On the other hand, the respondents, including A. Rajappa, argued that the Board’s activities fell within the scope of an industry as defined by the Act, and thus, its employees should be entitled to the benefits and protections accorded to workers in industries. The Supreme Court, in its judgment, undertook a comprehensive analysis of the term ‘industry.’ The bench, led by Chief Justice M. Hameedullah Beg, laid down a broad and inclusive definition of ‘industry.’ The Court asserted that what mattered was the nature of the activity and the relationship between the employer and the employees. This interpretation aimed to ensure that a wide range of workers, including those employed in public utility services, statutory bodies, and even some non-profit organizations, would be covered under the protective umbrella of the Industrial Disputes Act. The decision in Bangalore Water Supply v. A. Rajappa & Others had far-reaching implications. It extended the scope of labour protections to a broader spectrum of workers, ensuring that more employees could benefit from the dispute resolution mechanisms and other safeguards provided under the Industrial Disputes Act. This judgment underscored the judiciary’s role in interpreting labour laws to promote social justice and protect workers’ rights in a rapidly industrializing nation.
(Extract from Bangalore Water Supply v. A. Rajappa & Others, 1978 2 SCC)