*Bangalore Water Supply and Sewerage Board v. A. Rajappa* (1978)
The "Triple Test"
This 1978 judgment of a seven-judge Bench of the Supreme Court (AIR 1978 SC 548) is the foundational precedent on the meaning of "industry." It replaced earlier, narrower readings with a broad "triple test" that brought a wide range of establishments — including hospitals, educational institutions, and certain government departments performing non-sovereign functions — within the protective ambit of industrial law.
- The triple test asks whether there is (i) systematic activity, (ii) organised by cooperation between employer and employee, (iii) for the production or distribution of goods or services calculated to satisfy human wants and wishes — irrespective of profit motive
- The 1978 ruling was authored primarily by Justice V.R. Krishna Iyer and significantly expanded worker coverage compared to earlier case law
- The reference that led to the present nine-judge ruling originated in State of U.P. v. Jai Bir Singh, first referred for reconsideration by a five-judge Bench in 2005, and escalated to a nine-judge Bench by a seven-judge Bench in 2017 — a nearly two-decade-long pendency before final resolution in August 2026
● Tracked since August 21, 2026 · last seen August 22, 2026 · updates as the daily brief publishes
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