Industrial dispute scope under labour law depends on direct or substantial community of interest in the person's employment.

Section 2(k) of the Industrial Disputes Act does not treat every dispute concerning "any person" as an industrial dispute. The controlling test is whether the workmen, as a class, have a direct or substantial community of interest in that person's employment or non-employment, read in light of the Act's scheme and objects. A dispute involving a person outside the workman class can qualify only if that interest exists. On the facts, the person concerned belonged to the medical or technical staff, and the workmen had no such direct or substantial interest. The dispute therefore fell outside section 2(k), and the challenge failed.

---

---

Issues: Whether a dispute raised by workmen concerning the termination of service of a person who is not a workman falls within the definition of "industrial dispute" under section 2(k) of the Industrial Disputes Act, 1947.

Analysis: The definition in section 2(k) was read as consisting of a real dispute between the specified classes of parties and a subject-matter connected with the employment, non-employment, terms of employment, or conditions of labour of "any person". The expression "any person" was held not to be unlimited in its literal breadth. Construing the Act as a whole, and having regard to its scheme, objects, and related provisions, the controlling consideration was whether the workmen as a class had a direct or substantial interest in the employment or non-employment of the person concerned. A dispute relating to a person outside the workman class could therefore qualify only where a community of interest existed between the workmen and that person. On the facts, the person concerned belonged to the medical or technical staff and the workmen had no direct or substantial interest in his employment or non-employment.

Conclusion: The dispute did not amount to an industrial dispute under section 2(k), and the challenge failed.

Final Conclusion: The appeal could not succeed because the reference was outside the statutory concept of an industrial dispute on the facts found.

Ratio Decidendi: The words "any person" in section 2(k) are controlled by the scheme of the Act and apply only where the workmen have a direct or substantial community of interest in the subject-matter of the dispute.

---