Pure research and government benefit do not make a research institute an industry under section 2(j).

Section 2(j) of the Industrial Disputes Act applies only where there is systematic activity organised through employer-employee cooperation and the activity is analogous to trade or business. A research institute may qualify if its work is commercial or service-oriented and its output is meant for use or sale. Pure research undertaken for governmental benefit, without material showing marketability, commercial exploitation, or satisfaction of consumer needs, falls outside the definition of industry. The Physical Research Laboratory was therefore held not to be an industry under section 2(j), and the Labour Court award was set aside.

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Issues: Whether the Physical Research Laboratory is an industry within the meaning of section 2(j) of the Industrial Disputes Act.

Analysis: The controlling test for industry is whether there is systematic activity organised by cooperation between employer and employee for the production or distribution of goods or services calculated to satisfy human wants and wishes. The wide language of section 2(j) is not to be stretched beyond its functional setting, and the concept of industry applies only where the activity bears analogy to trade or business. Research institutes may fall within the definition when their work is of a commercial or service-oriented character and the results are meant for use or sale. But where the institution is engaged in pure research for governmental benefit, with no material showing that the knowledge produced is marketable, commercially exploitable, or intended to satisfy consumer needs, the activity is not analogous to trade or business. A governmental or sovereign character of the undertaking also weighs against classification as an industry.

Conclusion: The Physical Research Laboratory is not an industry within section 2(j) of the Industrial Disputes Act; the appeal was therefore allowed and the Labour Court award was set aside.

Ratio Decidendi: A research institute engaged in pure, non-commercial research for governmental benefit, whose results are not produced or distributed as services for satisfying human wants, is not an industry under section 2(j) of the Industrial Disputes Act even if its work is carried on systematically with employee cooperation.

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