Case Commentary on Bangalore Water Supply Sewerage Board v. A. Rajappa (1978) 2 SCC 213
A. Elakkiyapriya
G. Abinaya
A. Elakkiyapriya & G. Abinaya, Case Commentary on Bangalore Water Supply Sewerage Board v. A. Rajappa (1978) 2 SCC 213, Vol. 12 Iss 1 (1), IJLR (2026)
Abstract
Labour Law is a crucial legal area that significantly impacts the daily lives of individuals. Consequently, the case Bangalore Water Supply Sewerage Board v. A. Rajappa is a landmark decision in Labour Law. The Supreme Court of India held that the Bangalore Water Supply and Sewerage Board is an ‘industry’ under the Industrial Disputes Act 1947. The court applied the ‘triple test’ of systematic activity, employer-employee cooperation and production or distribution of goods or services to determine the Board’s status. This ruling expanded the definition of ‘industry’ to include public utility services such as water supply and sewage treatment, thereby ensuring labour protections for workers. The judgement has far-reaching implications for labour laws workers’ rights and the scope of industrial disputes in India.
Keywords
Labour Law, Industrial Jurisprudence, Workers’ Rights, Public Utility Services
