ISSUE:
Whether the employees of the Madras Raj Bhavan are employed in an "industry" within the meaning of the Trade Unions Act, 1926, and thus entitled to register their union as a trade union under the Act?
Whether the Industrial Disputes Act and Trade Unions Act can be read together as forming one whole system?
Whether the Test of Cooperation between employers and employees has been satisfied in the present dispute?
Whether sale of unserviceable material and surplus garden produce amounts to a trade or business activity?
RULE:
The term "industry" includes any trade, business, manufacture, or undertaking which is broader than the common conception of trade or business and implies cooperation between the employer and employees for achieving a particular result.
To register a union under the Trade Unions Act, the employees must be engaged in an activity that qualifies as a trade or business.