GENERAL MANAGER, TELECOM vs A SRINIVASA RAO

The Supreme Court addressed whether the Telecom Department of the Union of India qualifies as an 'industry' under Section 2(j) of the Industrial Disputes Act, 1947. The Court held that the definition of 'industry' must be interpreted in light of the dominant nature test established in Bangalore Water Supply and Sewerage Board vs. A Rajappa, which remains binding. The Court noted that the amendment to the definition in 1982 is not yet in force, thus the existing definition applies, and the reference made under Section 10A of the Industrial Disputes Act is competent.