Supreme Court Triple Test Judgment

Notes

• The Supreme Court's nine-judge Bench reviewed the 'Triple Test' established in the 1978 Bangalore Water Supply and Sewerage Board (BWSSB) vs A. Rajappa case.
• The Triple Test defines an 'industry' under Section 2(j) of the Industrial Disputes (ID) Act, 1947, based on three conditions: systematic activity, employer-employee cooperation, and production/distribution of goods/services for human wants (excluding purely religious/spiritual activities).
• Under the Triple Test, profit motive is irrelevant, and only 'sovereign functions' are excluded from the definition of an industry.
• The Industrial Relations Code, 2020 (IRC) came into force on November 21, 2025, repealing the ID Act, 1947.
• The Supreme Court majority ruled that the BWSSB judgment will not serve as a 'sheet anchor' for interpreting Section 2(p) of the new IRC.
• Justice B.V. Nagarathna's dissent argued that the reference was unnecessary and the Triple Test remains a vital bulwark for workers in the post-1991 liberalized economy.
• The Triple Test serves to maintain industrial peace by balancing worker protections with regulated procedures for retrenchment and closure for employers.

Part of a longer story

This is day 4 of 5 in Supreme Court ruling on 'industry' definition under Industrial Relations Code, which has been running since 21 August 2026. Reading it whole is usually worth more than reading today alone — the exam asks how something developed.

• Supreme Court ruling on 'industry' definition Before
• Supreme Court judgment on 'industry' definition After
• The whole story 5 entries