Evolution Of The Definition Of Industries From Bangalore Water Supply To Jai Bir Singh

Abstract

At the outset, the Supreme Court clarified that the petitions forming the present batch had been instituted before the subsequent legislative changes. The reference was therefore examined in the statutory setting of Section 2(j) of the Industrial Disputes Act, 1947, and not by applying the later legislative regime as though it governed the original proceedings. The judgment discussed in this paper was delivered by a nine-Judge Bench of the Supreme Court on 20 August 2026 in State of Uttar Pradesh v Jai Bir Singh. The dispute began as a question whether the Social Forestry Department of a State is an &ldquo;industry&rdquo;, and the Bench answered the reference through five separate opinions rather than one common judgment.[1] The one point on which all nine Judges agreed is that disputes still pending under the 1947 Act must be decided on the Triple Test as it stood in 1978.[2] [1] The judgment carries the neutral citation 2026 INSC 897. See Supreme Court Observer, &lsquo;Definition of &ldquo;Industry&rdquo; - Case Page&rsquo; (Supreme Court Observer, last updated 25 August 2026) <https://www.scobserver.in/cases/uttar-pradesh-jai-bir-singh-definition-of-industry-case-background/> accessed 28 September 2026; Agatha Shukla, &lsquo;&ldquo;Triple Test&rdquo; For &ldquo;Industry&rdquo; Laid Down In 1978 Bangalore Water Supply Case Will Govern All Pending Disputes Under Repealed Industrial Disputes Act: Supreme Court&rsquo;s 9-Judges Bench Clarifies&rsquo; (Verdictum, 22 August 2026) <https://www.verdictum.in/supreme-court/state-of-uttar-pradesh-v-jai-bir-singh-2026-insc-897-1978-triple-test-for-industry-9-judge-bench-1620398> accessed 28 September 2026. [2] Namrata Banerjee and Debjani M, &lsquo;Definition of Industry | Judgement Summary&rsquo; (Supreme Court Observer, 21 August 2026) <https://www.scobserver.in/reports/definition-of-industry-judgement-summary-2/> accessed 28 September 2026; &lsquo;Understanding the Judgment of the 9-Judge Constitution Bench of the Apex Court in the BWSSB vs Rajappa Reference&rsquo; (All India Lawyers&rsquo; Association for Justice, 24 August 2026) <https://ailaj.wordpress.com/2026/08/24/understanding-the-judgment-of-the-9-judge-constitution-bench-of-the-apex-court-in-the-bwssb-vs-rajappa-reference/> accessed 28 September 2026.