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Question

In which one of the following judgments did the Supreme Court lay down the 'Triple test' in respect of the definition of 'industry' under the Industrial Disputes Act, 1947?

The correct answer is
Bangalore Water Supply and Sewerage Board v. R. Rajappa, AIR 1978 SC 548

The question asks which judgment by the Supreme Court established the 'Triple Test' to define what constitutes an 'industry' under the Industrial Disputes Act, 1947.

In the context of Indian law, the 'Triple Test' was devised to determine whether a specific activity qualifies as an 'industry' and is therefore subject to the provisions of the Industrial Disputes Act, 1947. This determination is crucial as certain legal protections and regulations apply to entities classified as 'industries.'

The judgment that laid down this 'Triple Test' is Bangalore Water Supply and Sewerage Board v. R. Rajappa, AIR 1978 SC 548. This landmark case expanded the scope of what could be considered an 'industry,' providing a comprehensive threefold test.

The 'Triple Test' is structured as follows:

  1. Systematic Activity: The activity must be organized and systematic.
  2. Cooperation between Employer and Employee: There must be cooperation between the employer and employees, aimed at producing goods or services.
  3. Production and Distribution of Goods and Services: The goal should be for the production and/or distribution of goods or services.

Other options in the question, such as:

  • State of Bombay v. the Hospital Mazdoor Sabha, AIR 1960 SC 610 - This judgment discussed broader aspects of labor laws but did not focus solely on the definition of 'industry.'
  • State of U.P. v. Jai Bir Singh, (2005) 5 SCC 1 - This case did not address the triple test for defining 'industry.'
  • M/s Bharti Airtel Limited v. A.S. Raghavendra [Civil Appeal No. 5187 of 2023] - This is a more recent case and not related to the definition of 'industry' using a triple test.

Therefore, the correct answer is the landmark case of Bangalore Water Supply and Sewerage Board v. R. Rajappa, AIR 1978 SC 548, which is seminal in interpreting the definition of 'industry' within the context of the Industrial Disputes Act, 1947.

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