ISSUE:
Whether the term "industry" in Section 2(j) of the Industrial Disputes Act of 1947 includes operations relating to the State's "social forestry" department, which primarily focuses on environmental welfare?
Whether the conflicting interpretations between Chief Conservator of Forests v. Jagannath Maruti Kondhare and State of Gujarat v. Pratamsingh Narsinh Parmar be revisited in light of the binding precedent set by Bangalore Water Supply and Sewerage Board v. A. Rajappa?
RULE:
An "industry" involves organized cooperation between employers and employees for producing goods or services aimed at satisfying human wants or needs, excluding sovereign functions like law enforcement, justice dispensation, or legislation.
The dominant nature test applies when entities perform both industrial and sovereign functions, focusing on the primary nature of their activities.