Does ‘industry’ mean the same in TUA and IDA?

Yes. The court read the IDA definition into the TUA because both laws cover the same labour field (pari materia).

Can R&D employees form a trade union?

Yes, if their organization runs systematic services like inspection, testing, consultancy, or production methods.

Is profit motive required to be an industry?

No. Lack of profit motive does not stop an establishment from being an industry if it provides organized, material services.

Was CMTI an industry?

Yes. Its design, testing, consultancy and sale of tools/know-how fit industrial activity under the IDA.

Central Machine Tool Institute v. Assistant Labour Commissioner

```

Quick Summary

The Karnataka High Court said the word “industry” in the Trade Unions Act (TUA) should be read like the Industrial Disputes Act (IDA) because both cover labour law. A research body can be an industry even without profit motive if it runs systematic, service-giving activities. So, CMTI staff could form a trade union.

Core idea: Profit motive is not required; organized services can still be “industry.”
Result: CMTI counted as an industry; union registration was valid.

Issues

Does “industry” in TUA match “industry” in IDA?
Can R&D employees form a union under the TUA?
Can IDA’s later definition be read into the TUA?
Does lack of profit motive stop an establishment being an “industry”?

Rules

Pari materia reading: Where laws share subject and purpose, an unclear term in one may be read using the other.
No profit motive needed: If there is systematic activity rendering material services, the body can be an “industry.”

Facts (Timeline)

CASE_TITLE

CMTI, an R&D body in Bengaluru, worked on machine tool design, testing, inspection, and methods.
It was government-funded; internal income was small.
Employees formed “CMTI Employees’ Association” and sought trade union registration.
Assistant Labour Commissioner registered the association as a union.
CMTI objected: “we are not an industry; we are research-only; no profit motive.”
Cancellation was refused; CMTI filed a writ in the High Court.

Timeline for CMTI industry and union registration dispute

Arguments

CMTI (Petitioner)

Pure research; not engaged in trade/commerce.
No profit motive; mostly grant-funded.
TUA “industry” should not follow IDA definition.

Employees/Registrar (Respondents)

Systematic services: design, testing, consultancy, know-how.
IDA and TUA are pari materia; use IDA meaning.
Profit motive is irrelevant to “industry.”

Judgment

Held

Pari materia: “Industry” in TUA is read in line with IDA.
No profit requirement: Organized services make the body an industry even without profit aim.
CMTI is an industry: Activities like consultancy, testing, and sales fit IDA’s industrial profile.
Union valid: Employees were entitled to trade union registration.

Judgment illustration for CMTI industry case

Ratio Decidendi

TUA and IDA move in the same labour field; adopt a common meaning of “industry.” Profit motive is not decisive. CMTI’s systematic services brought it within “industry,” enabling union rights.

Why It Matters

Sets guidance for labs, institutes, and tech bodies on union rights.
Stops narrow “profit-only” views of industry under labour law.
Promotes consistent reading across labour statutes.

Key Takeaways

“Industry” under TUA aligns with IDA.
Profit motive not essential for being an industry.
R&D bodies giving organized services can form unions.

Mnemonic + 3-Step Hook

Mnemonic: “PARI-PROOF” — PARI materia meaning; PROOF of services, not profits.

Match: Use IDA meaning for TUA.
Assess: Look for systematic, service activity.
Decide: If yes, staff are entitled to unionize.

IRAC Outline

Issue

Meaning of “industry” in TUA; union rights of R&D staff; role of profit motive.

Rule

Pari materia with IDA; profit motive not essential if systematic, material services exist.

Application

CMTI’s testing, design, consultancy, and sales show organized services to the community.

Conclusion

CMTI is an industry; union registration stands.

Glossary

Pari Materia: A method of reading related statutes together to harmonize meanings.
Industry: Under IDA: systematic activity with employer–employee cooperation providing goods/services.
Profit Motive: Intention to earn profit; not essential for “industry” in labour law.