SECRETARY, MADRAS GYMKHANA CLUB EMPLOYEES'UNION vs MANAGEMENT OF THE GYMKHANA CLUB

The Supreme Court held that a non-proprietary members' club, which employs 194 individuals and engages in various recreational activities, qualifies as an 'industry' under Section 2(j) of the Industrial Disputes Act, 1947. The Court clarified that the definition of 'industry' encompasses any trade, business, or undertaking that involves cooperation between employers and employees aimed at production or distribution of goods or services. The Industrial Tribunal's decision to reject the employees' bonus claim was overturned, affirming that the club's operations meet the criteria for an industrial dispute.