Municipal sanitation work can amount to industry, making employee disputes referable under labour law and sustaining reinstatement.

Municipal undertakings performing sanitation, conservancy and other public utility functions can fall within the statutory meaning of "industry" when construed broadly and purposively in light of modern industrial conditions. On that footing, a dispute between a municipality and its employees engaged in municipal sanitation and clerical work was an industrial dispute under the Industrial Disputes Act, so the Government's reference to the Tribunal was competent. The Tribunal's findings of victimisation and wrongful dismissal were also left undisturbed, as they did not justify writ interference absent grave miscarriage of justice or flagrant illegality. The award of reinstatement therefore stood.

---

---

Issues: Whether a dispute between a municipality and its employees engaged in municipal sanitation and clerical work is an industrial dispute within the Industrial Disputes Act, so as to sustain a reference to the Tribunal and the award of reinstatement.

Analysis: The definitions of "industry", "industrial dispute" and "workman" in the Act are of wide amplitude and must be construed in the setting of modern industrial conditions. The inclusion of undertakings carried on by or on behalf of a local authority, together with public utility services such as sanitation, conservancy, water and lighting, shows that municipal activities are not excluded merely because they are performed by a statutory body and not for profit. The Court applied a broad and purposive construction, holding that disputes arising out of municipal operations analogous to trade or business fall within the statutory conception of industrial dispute. It further noted that the Government's jurisdiction to make a reference depends on the existence of such a dispute, and that the Tribunal's finding of victimisation and wrongful dismissal was not open to interference in writ proceedings absent grave miscarriage of justice or flagrant illegality.

Conclusion: The dispute was an industrial dispute within the Act, the reference was competent, and the award could not be disturbed.

Ratio Decidendi: Municipal undertakings carrying on activities analogous to trade or business, including public utility and sanitation services, fall within the statutory meaning of industry, and a dispute between such a municipality and its employees can constitute an industrial dispute amenable to reference under the Industrial Disputes Act.

---