Wide definition of industry under labour law covers a statutory water board despite public ownership and welfare functions

Section 2(j) of the Industrial Disputes Act was held to have wide amplitude, so an organised activity carried on with employer-employee cooperation for producing or distributing goods or rendering material services can constitute an industry. The dominant nature of the activity was treated as the decisive test, and neither absence of profit motive nor public ownership excluded the undertaking. Public utility undertakings and statutory bodies were therefore not outside the definition merely because they served welfare functions. Only strictly sovereign functions and a narrow residue of clearly non-industrial activities were kept outside the statutory concept; on that basis, the water board fell within industry and its appeal failed.

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Issues: Whether the Bangalore Water Supply and Sewerage Board answered to the statutory concept of "industry" under section 2(j) of the Industrial Disputes Act, 1947, and whether the Board's appeal against the contrary view could succeed.

Analysis: The definition in section 2(j) was held to be of wide amplitude, covering systematic and organised activity carried on with the cooperation of employer and employee for the production or distribution of goods or for the rendering of material services to satisfy human wants. The dominant nature of the activity, not the profit motive or the corporate character of the employer, was treated as the decisive test. Public utility undertakings, statutory bodies, and similar organised enterprises were not excluded merely because they were publicly owned or performed welfare functions. At the same time, truly sovereign functions and a narrow residue of purely self-serving or non-industrial activities were recognised as outside the definition. Applying these principles, the Board's undertaking fell within the statutory meaning of industry.

Conclusion: The appeal failed and the Board was held to be engaged in an industry within section 2(j).

Ratio Decidendi: An organised activity carried on with employer-employee cooperation for the production or distribution of goods or material services is an industry if its dominant nature is industrial, and neither absence of profit motive nor public ownership by itself takes it outside section 2(j), save for strictly sovereign functions and clearly non-industrial exceptions.

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