What question did the Court decide?

Whether a statutory water and sewerage board is an “industry” under Section 2(j) of the Industrial Disputes Act, 1947.

What is the Triple Test?

Systematic activity + employer–employee cooperation + production of goods/services for human needs (profit motive not required).

What is the Dominant Nature Test?

If mixed functions exist, look at the main, predominant activity to decide whether the entity is an industry.

Are public utility services sovereign?

No. Essential utilities like water/sewerage are public services but not strictly sovereign like defence or courts.

Who gets protection after this ruling?

Employees of such bodies qualify as workmen under the ID Act and can approach labour courts for disputes.

Bangalore Water Supply & Sewerage Board v. A. Rajappa

Quick Summary

This case gives the famous, wide meaning of “industry.” The Court said: look at the real work. If there is a system of work, employers and employees working together, and a service or good for people, it is an industry—even when run by law or without profit. Only narrow, strictly sovereign tasks (defence, courts, law-making) are excluded.

Hero image for Bangalore Water Supply v. Rajappa case explainer

Issues

Can a statutory utility that supplies water and manages sewerage be an “industry” under Section 2(j) of the ID Act, 1947?

Rules

Triple Test: (1) Systematic activity, (2) employer–employee cooperation, (3) goods/services for human needs (profit motive not required).

Dominant Nature Test: If some functions are industrial and some are not, the main, predominant function decides. Only strictly sovereign work is outside the Act.

Facts — Timeline

Penalties: The Board fined some employees for alleged misconduct.

Challenge: Staff moved the Labour Court under Section 33C(2), saying natural justice was not followed.

Board’s Stand: Claimed it was performing sovereign, governmental duties; therefore, not an “industry.”

Labour Court: Rejected the claim; held the Board is an industry.

High Court: Agreed with the Labour Court.

Supreme Court: Final appeal on the scope of “industry.”

Case timeline for Bangalore Water Supply v. Rajappa

Arguments

Employees (Respondents)

Water and sewerage work is organised and continuous.
It runs through employer–employee cooperation.
It provides a vital service to the public → industry.

Board (Appellant)

Functions are governmental and for public welfare.
Hence, the Board should be outside labour law.
Employees are not “workmen” under the Act.

Judgment

The Supreme Court held the Board is an “industry.” Water supply and sewerage are systematic services run through employer–employee cooperation for human needs. These are not strictly sovereign tasks. Employees are “workmen,” so the ID Act applies, and labour forums can hear their disputes.

Ratio

Broad meaning of “industry”: If the triple test is met, the activity is an industry. Exclude only narrow, core sovereign functions. Use the dominant nature test when functions are mixed.

Why It Matters

Anchor case for the ID Act’s reach—frequently asked in exams.
Protects staff in public utilities by confirming “industry” status.
Gives clear tests for tribunals to apply.

Key Takeaways

Triple Test = system + cooperation + human-need service.
Profit motive is irrelevant.
Only strictly sovereign work is outside the ID Act.
Use dominant nature test for mixed functions.

Mnemonic + 3-Step Hook

Mnemonic: “S-C-H” — System, Cooperation, Human-need service.

Spot the System: Is work organised and continuous?
Check Cooperation: Do employer and employees run it together?
Human Need: Does it deliver goods/services to people?

IRAC Outline

Issue	Is a statutory water/sewerage board an “industry” under Section 2(j) of the ID Act, 1947?
Rule	Apply the Triple Test and Dominant Nature Test; exclude only strictly sovereign functions.
Application	Board runs systematic, staff-driven services for public needs. Not sovereign. Main work is industrial in nature.
Conclusion	Board is an “industry”; employees are “workmen”; ID Act protections apply.

Glossary

Industry (ID Act): Organised activity with employer–employee cooperation that delivers goods/services to people.
Dominant Nature Test: When functions are mixed, the main, predominant activity decides the legal character.
Sovereign Function: Core State powers like defence, policing, courts, and legislation.