Question 1

The Supreme Court is currently hearing this case to interpret the new Labour Codes passed in 2020.

Accepted Answer

The Supreme Court is interpreting the Industrial Disputes Act, 1947. Even though the Industrial Relations Code 2020 exists, the 1947 Act still governs decades of pending cases and current disputes since the new codes are not fully implemented and do not apply retroactively.

Question 2

Government departments are automatically exempt from labour laws because they belong to the State.

Accepted Answer

Under the 1978 Bangalore Water Supply ruling, only strict 'sovereign functions' (like justice and defense) are exempt. Government welfare departments, like social forestry or irrigation, were classified as industries subject to labour laws.

Question 3

Consider the following statements regarding the definition of 'Industry' under Indian labour laws:
1. The 'Triple Test' for defining an industry was established by the Supreme Court in the State of UP v. Jai Bir Singh (2005) case.
2. According to the 1978 Supreme Court interpretation, the presence of a profit motive is an essential pre-requisite for an establishment to be classified as an industry.
3. The Industrial Disputes Act, 1947 defines 'industry' under Section 2(j).
How many of the above statements are correct?

Accepted Answer

(a) Only one — Statement 1 is incorrect; the Triple Test was laid down in the Bangalore Water Supply case (1978), not Jai Bir Singh (which actually referred the matter to a larger bench). Statement 2 is incorrect; the 1978 ruling explicitly stated that the absence of a profit motive is irrelevant. Statement 3 is correct; Section 2(j) of the IDA 1947 defines industry. Therefore, only one statement is correct.

Question 4

Match List I (Judicial/Legislative Milestone) with List II (Key Feature/Outcome):
List I:
A. Bangalore Water Supply Case (1978)
B. State of UP v. Jai Bir Singh (2005)
C. Section 2(j)
D. Industrial Relations Code (2020)

List II:
1. Statutory provision defining 'industry' in the IDA 1947
2. Established the 'Triple Test' expanding labour protections
3. Legislatively amends and consolidates labour definitions for the future
4. Questioned the 1978 ruling as overly worker-oriented and referred it to a larger bench

Select the correct code:

Accepted Answer

(b) A-2, B-4, C-1, D-3 — A matches with 2 (Bangalore Water Supply created the Triple Test). B matches with 4 (Jai Bir Singh in 2005 referred the matter, criticizing the previous ruling). C matches with 1 (Section 2(j) of IDA 1947 defines industry). D matches with 3 (The 2020 Code is the future legislative consolidation).

Question 5

Assertion (A): Following the 1978 Supreme Court judgment, employees of hospitals, universities, and charitable institutions were able to claim legal protections under the Industrial Disputes Act, 1947.
Reason (R): The Supreme Court in 1978 ruled that any systematic activity organized by cooperation between employer and employee for producing goods or services satisfies the test of an 'industry', regardless of whether it operates with a profit motive.

Accepted Answer

(a) Both A and R are true and R is the correct explanation of A — The Assertion is true as the Bangalore Water Supply case significantly expanded the ambit of 'industry'. The Reason is also true; this expansion was precisely because the Court formulated the 'Triple Test' (systematic activity, employer-employee cooperation, production of goods/services) and explicitly removed the requirement of a profit motive. Therefore, R directly explains why A happened.

SC 9-Judge Bench Hears 'Industry' Definition

Release of Women, Business and the Law 2026