Government Law Department not an industry under labour law; precedent must be applied only for its actual ratio and facts.

A Government Law Department is not an industry for purposes of the Industrial Disputes Act, 1947, so the definition of workman under Section 2(s) does not apply on that premise. The SC also held that precedent must be applied only for the principle actually decided and in the factual setting in which it arose; judicial observations cannot be treated as statutory text. On the facts, the accepted concept of industry was inapplicable to the Law Department, and the finding that it was an industry was unsustainable.

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Issues: Whether the Law Department of the Government can be treated as an industry for the purposes of the Industrial Disputes Act, 1947, and whether the termination dispute based on that premise was sustainable.

Analysis: The definition of workman under Section 2(s) applies only where the employee is employed in an industry. The Court held that the Law Department of the Government cannot, by any stretch, be regarded as an industry. It further held that the courts below erred in relying on earlier decisions without examining whether the factual setting of those cases matched the present one. A precedent binds only for the principle actually decided, and judicial observations cannot be treated as if they were statutory text. On the facts, the accepted concept of industry was inapplicable to the Law Department.

Conclusion: The finding that the Law Department was an industry was unsustainable. The appeal was therefore allowed in favour of the appellant.

Ratio Decidendi: A Government Law Department is not an industry for purposes of Section 2(s) of the Industrial Disputes Act, 1947, and precedent must be applied only according to its ratio and the facts on which it was decided.

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