Industry definition under the Industrial Disputes Act warrants larger Bench reconsideration amid conflicting precedent and dormant amendment.

The Supreme Court examined whether the definition of "industry" in Section 2(j) of the Industrial Disputes Act, 1947, as interpreted in Bangalore Water Supply, required reconsideration by a larger Bench. It noted conflicting later decisions on the scope of State welfare and social forestry activities, uncertainty over the reach of sovereign functions, and the fact that the 1982 amended definition had remained unimplemented for years. The Court also observed that Bangalore Water Supply was not wholly unanimous and that its interpretation was described as tentative pending legislative clarification. A larger Bench reference was therefore warranted to reconsider Section 2(j) and, if necessary, Bangalore Water Supply.

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Issues: Whether the definition of "industry" in Section 2(j) of the Industrial Disputes Act, 1947, as interpreted in Bangalore Water Supply and Sewerage Board, required reconsideration by a larger Bench in view of the conflicting later decisions, the differing views on sovereign functions, and the unimplemented amended definition introduced by the Industrial Disputes (Amendment) Act, 1982.

Analysis: The Court reviewed the earlier Constitution Bench decision and the later conflicting approaches of smaller Benches on whether State welfare and social forestry activities fall within "industry". It noted that Bangalore Water Supply was not a wholly unanimous decision, that the judges themselves described the interpretation exercise as tentative pending legislative clarification, and that the 1982 amendment to Section 2(j), though enacted, had remained unenforced for many years. The Court also considered the competing approaches on whether the Act should be read as a purely worker-oriented statute, whether sovereign functions should be confined to traditional governmental functions, and whether the amended but dormant provision could aid construction of the unamended definition.

Conclusion: A larger Bench reference was warranted for reconsideration of the interpretation of Section 2(j) and, if necessary, the Bangalore Water Supply decision.

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