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Court Rules 1978 'Industry'

Published 20 August 2026

The Supreme Court of India delivered a significant ruling on August 20, 2026, holding that a landmark 1978 interpretation of the term "industry" under the country's old labour law will not bind the definition in the new Industrial Relations Code, 2020. A nine-judge Constitution bench, by a 6-3 majority, decided that the expansive, worker-friendly definition from the 1978 Bangalore Water Supply case does not apply to the 2020 legislation, while clarifying that the older interpretation continues to govern disputes already pending under the now-repealed Industrial Disputes Act, 1947.

The bench, headed by Chief Justice of India Surya Kant, ruled that the reference to reconsider the 1978 verdict was validly made. Chief Justice Kant authored the majority opinion for himself and four other justices, holding that the future of the "industry" definition under the 2020 Code is not burdened by the 1947 Act's interpretation. The court explicitly stated it was not interpreting the new Industrial Relations Code itself.

The judgment stems from a decades-old question about the scope of the "triple test" formulated in the 1978 Bangalore Water Supply and Sewerage Board case. That test, authored...

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