Under Section 2(j) of the Industrial Disputes Act, 1947, 'industry' means any business, trade, undertaking, manufacture, or calling of employers and includes any calling, service, employment, handicraft, or industrial occupation or avocation of workmen. In the landmark Bangalore Water Supply case (1978), the Supreme Court laid down the: 

In Bangalore Water Supply and Sewerage Board v. A. Rajappa (1978), the Supreme Court laid down the 'triple test' for determining whether an activity constitutes an 'industry' under Section 2(j) of the Industrial Disputes Act. The three components are: (i) systematic activity, (ii) organised by cooperation between employer and employee, (iii) for the production and/or distribution of goods and services calculated to satisfy human wants and wishes (not spiritual or religious but inclusive of material things or services geared to celestial bliss). The Court held that even charitable, governmental, and non-profit activities could constitute 'industry' if they met this test. Sovereign functions (strictly governmental like administration of justice, legislation, and defence) were excluded.