State Of U.P vs Jai Bir Singh

The Supreme Court addressed the conflict between two prior decisions regarding the definition of 'industry' under Section 2(j) of the Industrial Disputes Act, 1947, specifically concerning the inclusion of the 'Social Forestry Department'. The Court held that the expansive interpretation of 'industry' from the Bangalore Water case is not universally applicable, emphasizing that not all welfare activities by the State qualify as 'industry'. The matter was referred to a larger bench due to the lack of consensus on the definition of 'sovereign functions' and its implications on the interpretation of 'industry'.