UPSC Prelims Practice Questions — How the SC ruling redefined ‘industry’

Q1. The seven-judge Bench decision of 1978 in Bangalore Water Supply and Sewerage Board v. A. Rajappa, which laid down the 'triple test' for classifying an activity as an 'industry', was led by which one of the following judges?

  • A. Justice P. N. Bhagwati
  • B. Justice Y. V. Chandrachud
  • C. Justice V. R. Krishna Iyer
  • D. Justice M. H. Beg

Q2. Which one of the following correctly describes the statutory basis on which the 1978 'triple test' was laid down, and the scope of the exclusion it recognised?

  • A. It interpreted Section 2(p) of the Industrial Relations Code, 2020, and held that all charitable institutions are permanently outside the term 'industry'
  • B. It interpreted Section 2(j) of the Industrial Disputes Act, 1947, and held that every activity carried on by a government department is entirely outside the term 'industry'
  • C. It interpreted Section 2(j) of the Industrial Disputes Act, 1947, and excluded only core sovereign functions such as the judiciary, defence and law enforcement
  • D. It interpreted Article 145(3) of the Constitution and held that only units engaged in manufacture of goods can ever be treated as an 'industry'

Q3. With reference to the verdict of the nine-judge Constitution Bench of the Supreme Court on the meaning of 'industry', consider the following statements: 1. It was delivered by a majority of 6:3. 2. Proceedings still pending under the Industrial Disputes Act, 1947 must continue to be decided on the basis of the 1978 triple test. 3. The majority held that the principles of the 1978 verdict shall not be treated as a sweeping anchor for interpreting the Industrial Relations Code, 2020. 4. The majority expressly overruled the 1978 judgment, so that disputes already concluded and settlements already reached under it may be reopened by employers. Which of the above is/are NOT correct?

  1. It was delivered by a majority of 6:3.
  2. Proceedings still pending under the Industrial Disputes Act, 1947 must continue to be decided on the basis of the 1978 triple test.
  3. The majority held that the principles of the 1978 verdict shall not be treated as a sweeping anchor for interpreting the Industrial Relations Code, 2020.
  4. The majority expressly overruled the 1978 judgment, so that disputes already concluded and settlements already reached under it may be reopened by employers.
  • A. 1 and 3
  • B. 2 and 4
  • C. 1, 2 and 4
  • D. 4 only

Q4. Consider the following statements comparing the 1978 ruling on 'industry' with the recent Constitution Bench verdict: 1. The recent majority located the meaning of 'industry' for the new labour code in Section 2(p) of the Industrial Relations Code, 2020, treating it as distinct from Section 2(j) of the Industrial Disputes Act, 1947. 2. The triple test was laid down by a Bench of nine judges, whereas the recent verdict was rendered by a Bench of seven judges. 3. Unlike the 1978 ruling, which construed a statute then in force, the recent verdict came after the Industrial Disputes Act, 1947 had been replaced with effect from 21 November 2025. Which of the statements given above is/are correct?

  1. The recent majority located the meaning of 'industry' for the new labour code in Section 2(p) of the Industrial Relations Code, 2020, treating it as distinct from Section 2(j) of the Industrial Disputes Act, 1947.
  2. The triple test was laid down by a Bench of nine judges, whereas the recent verdict was rendered by a Bench of seven judges.
  3. Unlike the 1978 ruling, which construed a statute then in force, the recent verdict came after the Industrial Disputes Act, 1947 had been replaced with effect from 21 November 2025.
  • A. 1 and 2 only
  • B. 1 and 3 only
  • C. 2 and 3 only
  • D. 1, 2 and 3

Q5. The minority opinion in the Constitution Bench verdict on 'industry' endorsed the 'dominant nature test'. This test involves examining which one of the following?

  • A. Whether the dominant share of an establishment's revenue is earned from the commercial sale of goods or services
  • B. The principal activity of an organisation that carries on several different functions, to decide whether it is an industry
  • C. Whether the employer occupies a dominant position in the market for the service that its workers help provide
  • D. Whether the predominant proportion of the workers of an establishment is engaged under written contracts of employment

Q6. In the Constitution Bench verdict on the meaning of 'industry', the principal majority opinion — written for the author and three other judges — was authored by which one of the following?

  • A. Justice P. S. Narasimha, who also delivered a separate opinion in the case
  • B. Justice Joymalya Bagchi, who also delivered a separate opinion in the case
  • C. Justice B. V. Nagarathna, who also delivered a separate opinion in the case
  • D. Chief Justice Surya Kant, who also headed the Bench in the case

Q7. With reference to the provisions of the Industrial Relations Code, 2020, consider the following: 1. Standing orders are required in an industrial establishment employing at least 300 workers. 2. Prior permission of the appropriate Government is required for lay-off, retrenchment and closure in an establishment employing at least 300 workers. 3. A trade union must have the support of at least 75 per cent of the workers of an establishment to be recognised as its sole negotiating union. 4. A notice of 14 days is required before a strike or lock-out, and such a notice remains valid for a maximum of 60 days. Which of the above is/are correctly identified?

  1. Standing orders are required in an industrial establishment employing at least 300 workers.
  2. Prior permission of the appropriate Government is required for lay-off, retrenchment and closure in an establishment employing at least 300 workers.
  3. A trade union must have the support of at least 75 per cent of the workers of an establishment to be recognised as its sole negotiating union.
  4. A notice of 14 days is required before a strike or lock-out, and such a notice remains valid for a maximum of 60 days.
  • A. 1 and 3 only
  • B. 1, 2 and 4 only
  • C. 2, 3 and 4 only
  • D. 1, 2, 3 and 4

Q8. Under the Industrial Relations Code, 2020, a worker aggrieved by discharge or dismissal may take the dispute directly to which forum, and after what period?

  • A. The conciliation officer of the appropriate Government, whose decision on the discharge or dismissal becomes final after 45 days
  • B. The Grievance Redressal Committee of the establishment, which the worker may approach after 45 days from making the application for conciliation
  • C. The Industrial Tribunal constituted under the Code, which the worker may approach after 45 days from making the application for conciliation
  • D. The National Industrial Tribunal constituted by the Central Government, which the worker may approach after 45 days from making the application for conciliation

Q9. The four Codes that rationalise 29 central enactments relating to wages, industrial relations, social security and occupational safety were brought into force by which authority, and with effect from which date?

  • A. Ministry of Corporate Affairs, with effect from 21 November 2025
  • B. Ministry of Labour and Employment, with effect from 21 November 2025
  • C. Ministry of Labour and Employment, with effect from 23 September 2020
  • D. Ministry of Skill Development and Entrepreneurship, with effect from 28 September 2020

Q10. Which one of the following statements about the enactment and scope of India's four labour Codes is correct?

  • A. The Code on Wages was enacted in 2019 and the other three Codes in 2020, and together they rationalise 29 central labour enactments
  • B. All four Codes were enacted in 2020, and together they replace every labour law in force in India, whether made by Parliament or by the States
  • C. All four Codes were enacted in 2019, and each one of them by itself repeals the entire set of 29 central labour enactments
  • D. The Code on Social Security was enacted in 2019 and the other three in 2020, and together they wholly displace the Factories Act, 1948 and all State shops legislation

Q11. With reference to Constitution Benches of the Supreme Court of India, consider the following: 1. Article 145(3) requires a minimum of five judges to decide a case involving a substantial question of law as to the interpretation of the Constitution. 2. The same minimum strength applies to the hearing of a reference made to the Supreme Court by the President under Article 143. 3. The question of the meaning of 'industry' was referred to a larger Bench by a three-judge Bench headed by the Chief Justice of India. 4. A Constitution Bench is a permanent Bench of the Supreme Court that sits throughout the year to hear constitutional matters. Which of the above is/are correctly identified?

  1. Article 145(3) requires a minimum of five judges to decide a case involving a substantial question of law as to the interpretation of the Constitution.
  2. The same minimum strength applies to the hearing of a reference made to the Supreme Court by the President under Article 143.
  3. The question of the meaning of 'industry' was referred to a larger Bench by a three-judge Bench headed by the Chief Justice of India.
  4. A Constitution Bench is a permanent Bench of the Supreme Court that sits throughout the year to hear constitutional matters.
  • A. 1 and 4 only
  • B. 2 and 3 only
  • C. 1, 2 and 3 only
  • D. 1, 3 and 4 only

Q12. Consider the following statements regarding the effect of the recent verdict on hospitals, educational institutions and charitable bodies: 1. The Industrial Relations Code, 2020 expressly keeps out of 'industry' institutions wholly or substantially engaged in charitable, social or philanthropic service — an exclusion the 1978 triple test did not apply. 2. Workers of establishments held to fall outside the Code's definition would lose retrenchment and lay-off protection and access to industrial-dispute adjudication, but would retain contractual and wage claims, social-security benefits and protection against discrimination. 3. The 1978 test had kept hospitals and educational institutions outside 'industry', and it is the Code of 2020 that brings them within that term for the first time. Which of the statements given above is/are correct?

  1. The Industrial Relations Code, 2020 expressly keeps out of 'industry' institutions wholly or substantially engaged in charitable, social or philanthropic service — an exclusion the 1978 triple test did not apply.
  2. Workers of establishments held to fall outside the Code's definition would lose retrenchment and lay-off protection and access to industrial-dispute adjudication, but would retain contractual and wage claims, social-security benefits and protection against discrimination.
  3. The 1978 test had kept hospitals and educational institutions outside 'industry', and it is the Code of 2020 that brings them within that term for the first time.
  • A. 1 only
  • B. 1 and 2 only
  • C. 2 and 3 only
  • D. 1, 2 and 3