ISSUE:
Whether a statutory body engaged in activities essential for the provision of basic amenities to citizens can be classified as an “industry” under the definition in Section 2(j) of the Industrial Disputes Act 1947?
RULE:
Dominant nature test, which applies when an entity performs both industrial and non-industrial functions. The dominant or predominant nature of the entity's activities determines whether the organization qualifies as an industry. Only strictly sovereign functions, such as defense and law enforcement, are excluded from the definition of "industry."
Triple test to determine whether an entity qualifies as an industry:
Systematic Activity: The entity must engage in an organized and systematic activity.
Employer-Employee Cooperation: The activity should involve the cooperation of employers and employees.
Production of Goods or Services for Human Needs: The activity must produce goods or services intended for human consumption or use, whether or not for profit.