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Nine-Judge SC Bench Upholds IRC 2020 Industry Definition; 1978 Triple Test Limited to Past Disputes

PolityCORE
Target:UPSC GS-IIMPSCTeachingSSC GABankingPrelims HighMains HighStatic GK Link
20 Aug 2026
~2 min
Source: The Hindu
Key Data:9-judge benchSection 2(j) ID Act 1947Section 2(p) IRC 2020Triple test1978 Bangalore Water Supply case
Bodies:Supreme Court
Practice MCQs from today's news ▸
What This Article Covers

1.SC upheld definition of 'industry' under IRC 2020 Section 2(p), clarifying it is independent of the 1978 interpretation.

2.The triple test from the 1978 Bangalore Water Supply case will not influence future interpretation under the new code.

3.Only core sovereign activities (judiciary, law & order, defence) are exempt from the definition of 'industry'.

The Big Picture
Prelims · HighMains · High

The Supreme Court's nine-judge bench has settled the law on the definition of 'industry' under the Industrial Relations Code 2020, ruling that the expansive triple test from the 1978 Bangalore Water Supply case applies only to pending disputes under the old Industrial Disputes Act. This judgment is essential for understanding the transition in labour law and the scope of judicial interpretation.

Exam Lens

Quick Exam Facts From News

Key ProvisionSection 2(p) of IRC 2020
Triple Test ElementsSystematic activity, employer-employee cooperation, production of goods/services
ExemptionCore sovereign functions only

1-Minute Revision

  • ›Key Provision: Section 2(p) of IRC 2020
  • ›Triple Test Elements: Systematic activity, employer-employee cooperation, production of goods/services
  • ›Target this Data: 9-judge bench
  • ›Target this Nodal Body: Supreme Court
  • ›Target this Legal Point: Section 2(p) of IRC 2020

Mastered this topic? Test your knowledge with a full MCQ quiz.

Practice exam-style questions, track your score, and strengthen your recall.

Q1Static LinkageEasy

Which Act's definition of 'industry' was under consideration in the 1978 Supreme Court judgment?

Q2Statement-basedHard

Consider the following statements:

1. The 2026 Supreme Court judgment held that the triple test from 1978 applies to disputes under IRC 2020.

2. Only core sovereign activities are exempt from the definition of 'industry' under the 1978 judgment.

3. The nine-judge bench clarified that Section 2(p) of IRC 2020 is not influenced by the 1978 interpretation.

Which of the statements given above is/are correct?

Q3Data-centricEasy

How many judges constituted the bench that delivered this judgment?

Q4Application/ImpactMedium

What is the primary implication of this judgment for future industrial disputes?

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