The term ‘industry’ means any business, trade, undertaking, manufacture or calling of employers and includes any calling, service, employment, handicraft, or industrial occupation or avocation of workmen. The definition of industry is a comprehensive definition and it is in two parts- one is from the point of view of the employers and the other is from the point of view of the employees. n the case of Madras Gymkhana Club Employees’ Union v. Madras Gymkhana Club, it was held that these two notions were in the definition, where first part relates to employers and the second relates to workmen. In Safdarjung Hospital v. Kuldeep Singh, it was held that it can be read as a collective enterprise where both workmen and employers are associated. Undertaking definition was given in the case state of Bombay v. Bombay mazdoor sabha sabha, and the definition expanded to systematic business or work with production or distribution of goods and services. As a working principle, it held in this case further that an activity systematically or habitually undertaken for the production or distribution of goods or for the rendering of material services to the community at large or a part of such community with the help of employees is an undertaking.

Bangalore Water Supply and Sewerage Board v. A Rajappa held that, 

it would be industry it they fulfil the triple test laid down in this A rajappa case:-

1. a systematic activity,
2. organised by co-operation between employer and employee (the direct and substantial element is commercial),
3. for the production and/or distribution of goods and services calculated to satisfy human wants and wishes (not spiritual or religious) but inclusive of services geared to celestial bliss, of material things, prima facie, there is an “industry” in that enterprise. This is known as triple test.

In the BWSSB V. A rajappa case, it was held that spiritual or religious services were not an industry. Absence of motive of gaining profit is irrelevant in any sector because if an organisation is philanthropic and does trade or business it will still be considered an industry. Therefore, after BWSSB v. rajappa case, it was stated that if, 

•  clubs
• cooperative society
•  research institutes
• charitable institutions
• educational institutions

If they Satisfy the triple test in the case, then they may be categorised as an industry.

 EXCEPTIONS

•  Casual activity
•   Small clubs, reseach labs without employee character
•  Selfless charitable activities carried through volunteering
•  Sovereign function.

Therefore, the term industry was given a new scope of definition under the triple test given in the case of  Bangalore Water supply and Sewerage Board v. A Rajappa. This has been applied to many more cases since the landmark judgment.

This Article Does Not Intend To Hurt The Sentiments Of Any Individual Community, Sect, Or Religion Etcetera. This Article Is Based Purely On The Authors Personal Views And Opinions In The Exercise Of The Fundamental Right Guaranteed Under Article 19(1)(A) And Other Related Laws Being Force In India, For The Time Being.