Supreme Court Reserves Judgment on Revisiting ‘Industry’ Definition in Bangalore Water Supply Case (2026)

Overview On 19 March 2026 , a nine‑judge bench of the Supreme Court headed by Chief Justice Surya Kant reserved its verdict on whether the broad definition of industry in the 1978 Bangalore Water Supply judgment should be revisited. The case pits the original “triple test” against the definition adopted in the Industrial Relations Code, 2020 , raising questions about the reach of labour legislation over welfare and sovereign functions. Key Developments Attorney General R. Venkataramani argued that Justice Iyer’s triple test, while logical, is overly broad and should not cover welfare‑related sovereign activities under the Industrial Disputes Act, 1947 . Additional Solicitor General K.M. Nataraj and senior advocates from Maharashtra, Punjab and Uttar Pradesh urged a broader interpretation, citing the 2020 Code’s “activities relatable to sovereign functions”. Senior advocates Indira Jaising , C.U. Singh and others contended that the definition must not be narrowed, emphasizing the worker‑centric nature of the 1947 Act. Amicus curiae JP Cama and P. Sengupta presented divergent views on the relevance of the employer‑employee relationship and the role of charity in defining industry. Important Facts The original triple test includes (i) existence of a systematic activity, (ii) employer‑employee relationship, and (iii) profit motive, though Iyer later said profit motive is irrelevant. The 2020 Code adopts Iyer’s test but expressly excludes charitable, philanthropic and sovereign activities, a departure from the 1978 judgment. Reference to the Safdargunj case was made to argue about unanimity and the impact of overturning precedent. Arguments invoked the Directive Principles of State Policy to stress the social‑justice orientation of labour law. UPSC Relevance The issue sits at the intersection of constitutional law (GS2) , labour & industrial relations (GS3) , and the policy‑making process (GS1 & GS4) . Aspirants should understand: How judicial interpretation can reshape statutory definitions and affect millions of workers. The balance between sovereign functions and private‑sector regulation. The role of amicus curiae in assisting the Court on complex policy matters. Implications for future amendments to labour codes and the protection of workers in non‑profit sectors. Way Forward While the judgment is pending, the debate signals a possible recalibration of the Industrial Disputes Act framework. Law‑makers may consider: Clarifying the scope of “industry” to explicitly include or exclude charitable and sovereign activities. Amending the 2020 Code to align with constitutional values enshrined in the Directive Principles . Ensuring that any reinterpretation does not create legal uncertainty for existing industrial tribunals and their remedial powers. For UPSC preparation, focus on the evolution of labour law jurisprudence, the interplay between statutory definitions and constitutional principles, and the potential impact on workers’ rights across sectors.