2025 · Q44
In which one of the following judgments did the Supreme Court lay down the 'Triple test' in respect of the definition of 'industry' under the Industrial Disputes Act, 1947?
Industrial Relations and Labour LawsIndustrial Disputes Act, 1947
- AState of Bombay v. the Hospital Mazdoor Sabha, AIR 1960 SC 610
- BBangalore Water Supply and Sewerage Board v. R. Rajappa, AIR 1978 SC 548
- CState of U.P. v. Jai Bir Singh, (2005) 5 SCC 1
- DM/s Bharti Airtel Limited v. A.S. Raghavendra [Civil Appeal No. 5187 of 2023]
Explanation
The Supreme Court laid down the triple test for 'industry' (systematic activity, organised by cooperation between employer and employees, for production/distribution of goods and services) in Bangalore Water Supply and Sewerage Board v. R. Rajappa (1978). The Hospital Mazdoor Sabha case (1960) gave an earlier narrower view, while the other two cases came later and did not lay down the test.