Definition of 'Industry' Under Industrial Relations Code, 2020: Supreme Court to Hear Challenge Based on ‘Triple Test’ Criteria

The Supreme Court has agreed to examine a legal challenge against the definition of 'industry' under the Industrial Relations Code, 2020, which is central to determining worker protections. The challenge, filed by a trade union, argues the new definition is vague and excludes crucial sectors, while the Court's recent nine-judge bench had earlier delinked the new definition from a landmark 1978 'triple test' precedent.

• ⚖️Legal Challenge

  The Supreme Court has agreed to hear a petition challenging the definition of 'industry' under the new Industrial Relations Code, 2020.

• 📜The 'Triple Test'

  The challenge argues the new definition fails the 'triple test' established by a 1978 Supreme Court judgment for determining what constitutes an industry.

• 🔗Judicial Delinking

  A recent nine-judge bench held that the new Code's definition is not bound by the 1978 interpretation, making the current challenge crucial for future labor law.

Industrial Relations Code (IRC), 2020

One of the four new labor codes that consolidates and amends laws related to trade unions, industrial disputes, and working conditions. It subsumes the Industrial Disputes Act, 1947, the Trade Unions Act, 1926, and the Industrial Employment (Standing Orders) Act, 1946.

Bangalore Water Supply Case (1978)

A landmark Supreme Court judgment by a seven-judge bench that laid down the 'triple test' to define 'industry'. It held that any systematic activity organized with employer-worker cooperation for producing goods/services to satisfy human wants is an industry, significantly widening its scope.

Triple Test (for Industry)

The three-pronged test established in the Bangalore Water Supply case: 1) Systematic activity, 2) Organized by cooperation between employer and workers, 3) For production/supply/distribution of goods/services to satisfy human wants. All three must be satisfied.

• Legal Point: Definition of 'industry' under Section 2(p) of the Industrial Relations Code, 2020.
• Judicial Doctrine: The 'Triple Test' from the 1978 Bangalore Water Supply case.
• Case Law: Bangalore Water Supply and Sewerage Board v. A. Rajappa (1978).

1. Q1Easy

   The definition of 'industry' is provided under which section of the Industrial Relations Code, 2020?

   • ASection 2(p)
   • BSection 4(b)
   • CSection 2(j)
   • DSection 3(a)
2. Q2Hard

   Consider the following statements regarding the definition of 'industry':

   1. 1.The 'triple test' for defining industry was laid down by the Supreme Court in the Bangalore Water Supply case of 1978.
   2. 2.The Industrial Relations Code, 2020, explicitly includes all charitable and sovereign functions of the government within the definition of 'industry'.
   3. 3.A nine-judge bench of the Supreme Court in 2026 held that the definition under the new Code is not bound by the 1978 interpretation.

   Which of the statements given above is/are correct?

   • AOnly 1
   • BOnly 2
   • CBoth 1 and 3
   • DAll three
3. Q3Medium

   The petition challenging the definition of 'industry' under the IRC, 2020, was filed by which trade union, as per the news article?

   • ABharatiya Mazdoor Sangh (BMS)
   • BAll India Trade Union Congress (AITUC) Tamil Nadu
   • CCentre of Indian Trade Unions (CITU)
   • DIndian National Trade Union Congress (INTUC)
4. Q4Medium

   What is the primary legal concern raised in the petition against the definition of 'industry' in the Industrial Relations Code, 2020?

   • AIt imposes excessive compliance burdens on micro-enterprises.
   • BIt conflicts with the definition provided in the Constitution of India.
   • CIts vague language and broad exemptions may deny legal protections to workers.
   • DIt makes the code applicable only to the private sector.

• Original28 October 2026 · Read story