Broad definition of industry applied to municipal services, while primary sovereign functions and purely regal activities remained excluded.

The definition of "industry" under the Act was construed broadly to cover organised municipal activities viewed from the standpoint of employer and employee, and not confined to trade or business. Municipal services that could also be performed by private persons for remuneration were held capable of falling within the term. The doctrine of noscitur a sociis could not narrow the statutory language. Primary and inalienable sovereign functions of the State, however, remained excluded. For departments performing mixed functions, the predominant activity controlled their legal character, and connected administrative or financial wings followed that main activity. On this basis, the relevant municipal departments were treated as industries, subject to exclusion of regal functions.

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Issues: Whether the municipal corporation's activities fell within the definition of "industry" under the Act, and whether regal functions were excluded from that definition.

Analysis: The definition of "industry" was held to be of wide amplitude, extending to organized activities viewed from the standpoint of both employer and employee. The Court rejected a narrow construction confined to trade or business and held that municipal services may constitute industry if they are comparable to services that could be undertaken by private persons for remuneration. It also held that the doctrine of noscitur a sociis could not be used to curtail the plain width of the statutory definition. At the same time, primary and inalienable sovereign functions of the State were excluded. Where a municipal department performed mixed functions, the relevant criterion was whether its predominant functions were industrial, and the connected administrative or financial wings would follow the character of the main activity. Applying these principles, the Court found that the impugned municipal departments, other than the excluded sovereign or non-industrial functions, were within the Act.

Conclusion: The municipal corporation's relevant departments were industries within the meaning of the Act, excluding regal functions.

Ratio Decidendi: A municipal service is an industry if it is an organized activity that could be undertaken by a private person, but primary sovereign functions and purely regal functions of the State are excluded; in mixed departments, the predominant function determines the legal character.

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