Agricultural Produce Market Committee v. Ashok Harikuni (2000) 8 SCC 61

AGRICULTURAL PRODUCE MARKET COMMITTEE V. ASHOK HARIKUNI

Whether the Agricultural Produce Marketing (Regulation) Committee (APMC) created under the Karnataka Agricultural Produce Marketing (Regulation) Act, 1966, qualifies as an “industry” as defined by the Industrial Disputes Act, 1947 (IDA)?
Whether the Karnataka Act, having acquired the President’s assent, supersedes the IDA relevant to the employees controlled by the State Act?

A statutory body like the Agricultural Produce Market Committee (APMC) can be classified as an “industry” under Section 2(j) of the Industrial Disputes Act, 1947 if its functions are not sovereign in nature.
Regulatory functions that serve the public interest and involve systematic, organized activities (such as market regulation), even if non-profit, do not qualify as sovereign functions and thus fall within the scope of the IDA.

Seven employees of APMC were terminated.
The employees challenged their terminations in the Labour Court.
The Labour Court ruled in their favor, overturning their dismissals and ordering reinstatement.
The APMC filed a writ petition challenging the Labour Court’s ruling, claiming that because the APMC is not an “industry,” the Labour Court lacked authority to consider the cases.

The Supreme Court held that APMC’s functions, though for public benefit, do not qualify as sovereign functions.
The APMC regulates the marketing of agricultural produce and is engaged in organized, systematic activity with a predominant focus on providing services to the community. These are not inherently sovereign functions.
The Court ruled that the APMC qualifies as an “industry” under Section 2(j) of the Industrial Disputes Act, 1947. Therefore, the employees fall under the definition of “workmen” as per the Central Act, and the Labour Court has jurisdiction. The Karnataka Act does not exclude APMC employees from the IDA’s application, and the dismissal of the employees was rightly set aside.
The Court dismissed the appeal, upholding the High Court’s judgment that APMC is an industry, and confirmed the employees’ reinstatement.