UNIVERSITY OF DELHI & ANR. vs RAM NATH

The Supreme Court held that the University of Delhi and Miranda House do not constitute an 'industry' under Section 2(j) of the Industrial Disputes Act, 1947, as the primary activity of these educational institutions is imparting education, which is not industrial in nature. The Court reasoned that the work of education is primarily carried out by teachers, and the subordinate staff's role is minor and insignificant. Consequently, the Tribunal's order directing the appellants to pay retrenchment compensation under Section 33(c)(2) was set aside, affirming that educational institutions are excluded from the purview of the Act.