Is the Coir Board an “industry” under the ID Act?

Yes. The Supreme Court held the Coir Board carries out systematic and organised activities through employees; profit motive is not required.

Does a public, promotional body fall outside labour law?

No. If it runs organised work with employer–employee cooperation, it is an industry even if its aim is promotion, not profit.

What protection did employees get?

As workmen under the ID Act, their termination had to follow due process. Discharges without compliance were not valid.

Which legal tests mattered?

Systematic activity + employer–employee cooperation + service for human needs; focus on real, organised functioning.

What is the case citation?

Coir Board, Ernakulam v. Indira Devi P.S., (1998) 3 SCC 259.

Coir Board, Ernakulam v. Indira Devi P.S.

Quick Summary

Question: Is the Coir Board an “industry” under Section 2(j) of the ID Act, 1947? The Supreme Court said yes. The Board ran organised, ongoing work through employees—like showrooms and depots selling coir goods. Profit was not essential. Because it is an industry, its staff get ID Act protections against unlawful termination.

Hero image for Coir Board v. Indira Devi case explainer

Issues

Can the Coir Board be treated as an “industry” under Section 2(j) ID Act?
Do its promotional and regulatory roles take it outside labour law protections?

Rules

An “industry” covers any systematic and organised activity run through employer–employee cooperation for goods or services. Profit motive is irrelevant. What matters is the real working set-up and the presence of staff doing coordinated tasks.

Facts — Timeline

Creation: Coir Board set up by Coir Industry Act, 1953 to develop and promote the coir sector.

Operations: Ran showrooms and depots that sold coir products from registered private makers; earned commission.

Staffing: Employed clerks and typists to manage administration and sales operations.

Dispute: Some temporary clerks/typists were discharged; they invoked the ID Act for protection.

Kerala High Court: Held the Board is an “industry”; terminations must follow the ID Act.

Supreme Court Appeal: Board claimed it is a statutory promoter, not an “industry.”

Case timeline for Coir Board v. Indira Devi

Arguments

Employees (Respondents)

Board runs organised sales and admin work through staff.
Services aid the market and consumers → industry under Section 2(j).
Terminations must follow the ID Act’s due process.

Coir Board (Appellant)

Primarily a statutory promoter/regulator; not engaged in “industrial” activity.
Profit is not the aim; hence ID Act should not apply.
Discharges were within its administrative powers.

Judgment

The Supreme Court dismissed the appeal and confirmed that the Coir Board is an “industry.” Its organised work—sales depots, showrooms, administration—runs through employees. The absence of profit motive does not matter. Therefore, employee discharges must comply with the Industrial Disputes Act procedures.

Ratio

Function over label: Look at real, systematic activity with staff cooperation. Promotion or regulation can still be an industry if organised and service-oriented. Profit is not a condition.

Why It Matters

Confirms many statutory bodies fall within the ID Act.
Protects staff in promotional/regulatory organisations.
Guides tribunals to assess actual operations, not formal labels.

Key Takeaways

Industry = organised activity + employer–employee cooperation.
Profit motive is irrelevant under Section 2(j).
Statutory promotion and sales operations can qualify.
Terminations must follow ID Act procedure.

Mnemonic + 3-Step Hook

Mnemonic: “S-O-S” — Staff Cooperation, Organised Work, Service to Market.

Check Staff: Are employees running the activity?
See Organisation: Is the work systematic and ongoing?
Service Focus: Does it deliver goods/services, profit or not?

IRAC Outline

Issue	Is the Coir Board an “industry” under Section 2(j) of the ID Act, 1947?
Rule	Any organised activity with employer–employee cooperation producing goods/services counts; profit motive is not necessary.
Application	Board ran showrooms/depots and admin work via employees; activities were systematic and service-oriented.
Conclusion	Coir Board is an “industry”; staff are workmen; ID Act protections apply to termination.

Glossary

Industry (ID Act): Organised, staff-run activity delivering goods or services; excludes only strictly sovereign functions.
Workman: Employee covered by the ID Act, entitled to protections like due process on termination.
Retrenchment: Termination for reasons other than disciplinary action; must follow statutory steps.