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:
Section 2(j) of the Industrial Disputes Act, 1947 defines "industry" based on systematic operations involving employer-employee interactions, regardless of whether the objective is profit-making.
The key test is the nature of activities and employer-employee relations, not the presence of a profit motive.