Reconsidering the ‘Industry’ Doctrine: The Supreme Court’s Nine-Judge Review of Bangalore Water Supply v. A. Rajappa

Introduction Few judgments in the field of Indian labour laws have been as controversial as the judgment which was given in Bangalore Water Supply & Sewerage Board vs. A Rajappa (1978). In a judgment by a seven-judge bench, the Supreme Court had interpreted the term “industry” in Section 2(j) of the Industrial Disputes Act, (IDA) 1947 in such a way that it included within its ambit not just commercial enterprises and factories but also hospitals, charitable institutions, schools, and even...