মূল বিষয়

• The Supreme Court's 9-judge Constitution Bench ruled that the landmark 1978 expansive definition of 'industry' will not apply to interpretations under the new Industrial Relations Code (IRC), 2020.
• The 1978 Bangalore Water Supply and Sewerage Board (BWSSB) v. A. Rajappa judgment (authored by Justice V.R. Krishna Iyer) had introduced a 'triple test' (systematic activity, employer-employee cooperation, production of goods/services for human wants) that brought institutions like hospitals, educational bodies, and municipalities within the purview of worker-protection laws.
• The majority opinion, authored by Chief Justice Surya Kant, clarified that Section 2(p) of the IRC, 2020 (which came into force in November 2025) will be interpreted in its own text and context, unburdened by the 1978 precedent. This restricts the 1978 judgment's applicability strictly to pending legacy cases filed under the 1947 Act.
• In a strong dissent, Justice B.V. Nagarathna (supported by Justices Datta and Bhuyan) argued that the reference was unwarranted. She emphasized that post-liberalisation and privatisation, a broad definition of 'industry' is critical to safeguard the rights of workers transitioning from public to private sectors. She upheld the 1978 'Dominant Nature Test'.
• Justice Dipankar Datta highlighted the need for judicial consistency and finality, remarking that 'institutional credibility lies in respecting finality and not in perpetuating doubt'.
• The ruling marks a pivotal shift in Indian labour jurisprudence, decoupling modern economic-market labour reforms from 1970s welfare-oriented judicial interpretations.