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

COIR BOARD, ERNAKULAM V. INDIRA DEVI

Whether the Appellant can be classified as an industry under Section 2(j) of the Industrial Disputes Act 1947?

An ‘industry’ under Section 2(j) of the Industrial Disputes Act, 1947 refers to any systematic activity involving cooperation between employers and employees for the production of goods or services, regardless of whether the activity is profit-oriented.
The presence of an employer-employee relationship and organized functioning are the key determinants of an ‘industry’ under the Act.

The Appellants (Coir Board) had been set up in 1953 under the Choir Industry Act, and employed clerks as well as typists, who were suddenly discharged. The employees stated that their termination would only be valid if done so under provisions of the Industrial Disputes Act 1947.
The Kerala High Court considered the question and ruled that the Appellants were an industry as defined in the Industrial Disputes Act, and thus the termination was applicable. The matter was then appealed before the Supreme Court.

The Supreme Court upheld the Kerala High Court’s decision, concluding that the Coir Board does qualify as an ‘industry’ under the Industrial Disputes Act.
The court reasoned that under the expansive interpretation of the term ‘industry’ as established in the Bangalore Water Supply case, the Coir Board, despite being a statutory body for promoting the coir industry, employs workers and performs organized activities akin to an industry.
The court suggested that the broad interpretation of ‘industry’ should be reconsidered by a larger bench in the future but applied the existing law to hold that the Coir Board is subject to the Industrial Disputes Act.