A nine-judge Supreme Court bench ruled that the 1978 Bangalore Water Supply interpretation of 'industry' will not automatically carry over to the Industrial Relations Code 2020, which replaced the Industrial Disputes Act in November 2025.

The Supreme Court of India has ruled that the nearly 50-year-old interpretation of the term 'industry' will not automatically apply to the Industrial Relations Code (IRC), 2020. The IRC came into force in November 2025, replacing the Industrial Disputes Act, 1947.
The decision was made by a nine-member Constitution Bench. It effectively severs the new labour regime from the expansive interpretation established in the 1978 case Bangalore Water Supply and Sewerage Board v. R. Rajappa.
That 1978 ruling, authored by Justice V.R. Krishna Iyer, had significantly broadened the definition of 'industry' under Section 2(j) of the 1947 Act.
With the latest judgment, the Court has indicated that future labour law disputes under the new code will be considered on a clean slate, rather than being bound by the earlier worker-friendly interpretation. The full implications for labour disputes in India are yet to unfold.
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