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State of U.P. v. Jai Bir Singh (with connected appeals)

Civil Appeal · 2026 INSC 897Decided 20 Aug 2026
Civil Appeal No. 897 of 2002
Surya Kant, CJI · Justice Satish Chandra Sharma · Justice Alok Aradhe · Justice Vipul M. Pancholi · Justice B.V. Nagarathna · Justice Pamidighantam Sri Narasimha · Justice Dipankar Datta · Justice Ujjal Bhuyan · Justice Joymalya Bagchi

Background

The case asked whether U.P.'s Social Forestry Department, an environmental welfare scheme, counts as an "industry" under labour law, which would determine whether its workers get industrial-law protections. Filed in 2001, the appeal was progressively referred to larger and larger benches (three judges → five → seven → nine) as it came to be seen as the vehicle for reconsidering a foundational 1978 seven-judge ruling (Bangalore Water Supply & Sewerage Board v. A. Rajappa) that had broadly defined "industry", explaining why a single case remained pending for roughly 25 years.

Decision Breakdown

All nine judges, through differing reasoning, declined to overrule the 1978 "triple test" for identifying an industry. The lead opinion reaffirmed the test with a clarificatory reformulation, but limited its application to pending Industrial Disputes Act cases, not the newer Industrial Relations Code, 2020. Two judges held the 1978 ruling needed no reconsideration at all after nearly five decades of settled use. The final opinion rejected the idea that government welfare bodies are automatically shielded just because they serve a public purpose. The Court did not itself decide whether the Social Forestry Department qualifies: that goes back to smaller benches to apply the reaffirmed test.

Lesson Learnt

Nearly 50 years on, the wide definition of "industry" survives: government departments and welfare schemes are not automatically exempt from labour-law obligations just because they serve a public or charitable purpose; only genuinely sovereign, non-commercial state functions fall outside it, so workers in organised government undertakings generally keep their industrial-dispute remedies for matters predating the 2020 Code.

Official source (sci.gov.in)View Judgment (PDF)

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