On 21 February 1978, a seven-judge Constitution Bench laid down the triple test for 'industry' under s.2(j) of the Industrial Disputes Act, sweeping hospitals, clubs, and charities into its coverage.
On 27 January 2026, a two-judge bench of Justices Pankaj Mithal and S.V.N. Bhatti held that disputes relating to the employment, termination, or alleged sham nature of contract labour arrangements must be adjudicated by a Labour Court or Industrial Tribunal under the Industrial Disputes Act, 1947 — and that the State's reference jurisdiction operates even on an apprehended dispute and is not foreclosed by the absence of a prior written demand on the employer. The judgment reaffirms the SAIL safeguards for contract labour and supplies a working architecture for contract-labour litigation.